URC Review Draft
  S/11/2004
              United States
              Environmental
              Protection Agency
EPA Science Advisory
Board (1400A)
Washington DC
EPA-SAB-04-xxx
September 2004
www. epa. gov/s ab
&EPA  Review  of EPA's Draft  Report
              on  the  Environment 2003

                      <«QRC Review Draft »>
              A Report by

              The Science Advisory Board Panel on

              EPA's Report on the  Environment

                                 Note tti the Render

                   The iituichcd is ;i draft report of an expert Panel established by the I !.S. I-PA Science
              Advisory Hoard (SAB). The draft is still undergoing final inlcniiil SAB review, however, in its
              present form, il represents the consensus position ofihe |i;aiel imolvcd in ihe review. < >nce
              approved as I'imil. the report will be transmitted to the HI'A Administrator and \\ill beeoine
              available to the interested public as a Tina! report. The draft is no\\ being reviewed h\ (lie IT'A
              SAM QRC prior lo its delivery to the Chartered Hoard lor its consideration and approv al  During:
              the revie\\ of this draft repoit. both the UliC and the Board \\ill consider \\hether: 1 i the original
              charge questions to the SAH re\ ie\\ |ianel have been adequately addressed: 2) there are am
              technical errors or omissions or issues thai are inadequately dealt uith in the report. 3 i the report is
              clear and logical: and -I i am conclusions drawn or recommendations provided, are supported b\
              the body of information in the report

                   Tins draft is beiny released tor general information to members ofihe interested public
              and to IT'A staff.  Tins is consistent \\ ith the SAH polies of releasing draft materials onh when
              11 ic Committee involved is comfortable that the document is sufficiently complete to provide
              useful information to the reader. The reader should remember thai this is an imapprovcd working
              drafl and that Ihe document should not be used lo represent official H'A or SAB views or udviee.
              I )rall documents at this stage of the process often undergo significant revisions before the final
              version is approved and published.

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                     UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
-    *  •*                     WASHINGTON. D.C 20460
I,
                                                                 OFFICE OF THE ADMINISTRATOR
                                                                     SCIENCE ADVISORY BOARD
  The Honorable Michael Leavi .t
  Administrator
  U.S. Environmental Protection Agency
   1200 Pennsyl\ania A\enue. N W
  Washington. D.C.   20460

  Subject: Re\ieu ofEPA's Draft Report on the Environment -003
   Dear Administrator Leavitt:

     A Panel of the EPA Science Advisory Board (SAB) met on March (>-12. 2004 to re\ iew the
   Agency's Draft Report on the Environment 2003 (ROE:). The SAB Review Panel, known as the
   Advisory Panel on EPA's Report on the Environment, was composed of twenty scientists
   selected to pro\ ide expertise ir the broad range of topics addressed by the ROE

   The SAB finds that the ROE is a critically important document, prov iding the first national
   assessment of the em ironment in a context of human and ecological health There is an urgent
   need for  this kind of regular assessment.  The SAB therefore encourages continued significant
   effort in developing and impro\ ing the ROE and believes that EPA is the appropriate agency to
   lead this  effort The SAB prov ides a number of recommendations for improvements in future
   versions  of the ROE to make the document more useful to EPA and other intended audiences.

   SUMMARY OF RECOMMENDATIONS

   The SAB finds that EPA  should:

      •  Allocate funds and staff to ensure that the report is continued on a regular basis. In
         order to sustain this important effort over the long term, the SAB recommends that the
         EPA dedicate resources and a permanent team of staff to synihesi/e appropriate
         indicators and data for ihe next and future reports. The team should include statistical
         expertise, and should be assigned the ongoing tasks of pooling and analy/.ing data for the
         ROE and conducting more analvsis and svnthesis than was included in the draft ROE

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*  Keep the ROE Tree or conclusions about the impacts of specific policies or other
   government initiatives  It should be maintained as a Report on the Environment that
   reviews the status and trends of environmental conditions in the United Stales

•  Develop an expanded introduction to the ROE, defining the purposes of the
   document, describing the rationale behind the approach, and explaining the
   indicators and conceptual framework behind the structure. The organi/ational focus
   of the draft ROE on questions and indicators is basically sound.  However, the draft ROE
   fails to communicate a consistent and clear purpose or to provide an overarching
   framework for the document. This deficiency has had wide ranging effects on the
   document, including varied and inconsistent approaches to indicator selection, and
   une\ en treatment of indicator reliability.  The expanded introduction should include a
   discussion of how the indices and data presented in the air. water, and land chapters relate
   and merge into the o\erarching themes of interest in the document: human health and
   ecological condition.  The expanded introduction should:  provide a better explanation of
   the criteria for selecting the questions that are asked in the succeeding chapters, explain
   the concept of an indicator, explain what indicators were selected and \\liy they were
   selected, and distinguish among different and expanded categories of data available for
   the selected indicators. The SAB suggests that reasonable criteria for selecting indicators
   might include scientific defensibilily.  quantiliability, transparency, and consistency.

•  Reorganize the report to: provide greater consistency among the air, water, and
   land chapters; address linkages between exposure and human health in the human
   health chapter; and organize the ecological condition chapter around synthesis
   questions, with specific indicator data relocated  to other chapters. The chapter on
   human health impacts of pollution should devote greater attention to the linkages between
   exposure and health effects.  Some em ironmentally linked health effects are well
   established and should be presented as such without equi\ocation.  Other effects, which
   are suspected but less well established, can also be  discussed.  However, cataloging all
   causes of morbidity and mortality, most of which are not known or suspected of being
   related to the types of environmental exposures described in the air. water, and land
   chapters, seems less useful. The SAB commends the use of vignettes  or case studies
   focusing on specific pollutants (e.g.. lead). The approach to assessing ecological health
   should be restructured to mo\e away from reporting on isolated indicators such as the
   extent of forest land.  The approach should integrate indicators from across different
   locations (e.g..  air. water, and land) to assess different essential ecological  attributes
   (ERAs).  and then integrate multiple l;CAs to assess environmental health with respect to
   key ecological conditions. Questions addressing ecological health such as the status of
   biodiversity, fisheries health and suslainabilily. and element cycling could be used as
   organi/ing themes.  Regional and local data should be used to comey an accurate picture
   of trends and knowledge gaps. In  addition, the effect of ecologic changes on human
   disease (e.g.. Lyme disease. West Nile viral encephalitis) should be discussed

•  Incorporate regional indicators into the report when they can provide insight on
   national conditions.  Much can be inferred from data available at local and regional
   scales. National indicators can be built from local and regional data and measures.  Also.

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      QRC Revicu Draft
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  1          some em ironmenlal changes are best understood by considering regional impacts (e.g.
  2          air quality). Therefore, indicators in the next \ ersion of tlu: ROE should not be limited to
  3          those for \\hich data are available  at the national lev el.
  4
  5       •  Strengthen the report by adding certain key missing indicators and providing
 (••          additional information about indicators that are currently included in the report.
  7          Future versions of the IOE should distinguish between emitted (primary) pollutants and
 s          environmentally synthesi/ed (secondary) pollutants and discuss the concept of secondary
 <>          pollutant precursors.  Water quantity information should be added to future versions of
10          the ROE  Full coverage of the hydrologic cycle is  needed to complete the assessment of
11          status and trends in \va:er quality and other water-related aspects of the em ironment.
12          Information about groimdwater. large scale water availability, and human water use and
13          demands are missing from the draft ROE. The water and land chapters of future reports
14          should contain indicators thai address both the extent and quality of different land and
15          water ecosystem types  Contaminants in food and  diet are also a critical component of
ir.          en \ iron men 1 as it relates to human health and should  be included in future versions of the
17          ROE.  EPA should also rethink the indicator gap and limitations approach presented in
is          the draft ROE.  The incicalor gap  and limitations sections of the draft ROE contain an
19          assortment of qualifiers that either inappropriately  discourage the reader from believing
2n          the data presented, or lead the reader to correctly conclude that the indicator is unsuitable
21          as it is configured. Some water indicators presented in the draft ROE. such as dissohed
22          oxygen, chlorophyll, water clarity, and index of biotic integrity, \\ere not useful as
23          de\ eloped in the report.  The report appropriately discourages readers from believing the
24          data presented on these indicators. As staled below, future versions of the ROE should
25          include indicator data relevant to global climate change. Future \ersions of the ROE
26          should also identify useful indicators of either human or ecological health for which only
27          regional data, or no data, are currently available.
2S
29       •  Include analyses and presentations of much greater  statistical  rigor.  General lack of
 '.'          statistical analysis in the draft ROE seriously limits the  presentation and interpretation of
  I          status and trend information Future versions of the ROE should incorporate much more
 2          rigorous statistical analyses of human health and ecological condition indicator data in
 3          order to: develop informative syntheses and spatial displays, identify patterns, and depict
 4          trends.  Greater statistical rigor is  also needed in the description of pollution sources and
 5          post-emission transformations and transport.  In future versions of the ROE. EPA should
 6          not aggregate data into national averages and trends when such aggregation leads to a
            loss of information  Rather than using the work summaries of others. EPA should
 s          conduct more in-depth data analyses and present summary data, ranges, measures, and
 9          trends In addition, arbitrary measures of conditions such as "good" or "poor" should not
-in          be used in future versions of the ROE unless these  measures are the established norms in
41          the indices used and are valid conclusions that compare indicators on a national scale.
42          Uncertainties in data and interpretation should also be discussed.
43
44       •  Include indicator data relevant to global climate change. Omission of global climate
45          change in relation to anthropogenic air pollution, and its health and ecologic implications.
46          is a major defect in the draft ROE  Climate change is both a confounding and primary

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     (JRC Review Orall
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            drneroflhe state of the environment.  Tlierefore, lack of coverage of any aspect of
            climate change greally hampers the presentation and interpretation of main indicators
            and topics in the draft ROE. Future A ersions of the ROE should recogni/e (hat global
            climate change will have first order impacts on a wide range of environmental indicators.
            and through them on human health and environmental conditions.  Indicators related to
            global warming, such as changing air and \\ater temperature patterns, changing  ice
            formation and thawing patterns, trends in global concentrations of primary climate
            change gases, trends in U.S. emissions of these gases, and trends in scattering and
            absorbing aerosol particle concentrations, are \ery important and should be included in
            fuiure ROE documents.
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   •   Revise the draft ROE Public Report to include more graphics and make it user
       Friendly. The draft ROE I'nh/ic Report is a long but largely abstracted presentation of
       the draft ROE Tcchnicn/ Report.  The i'ublic Report should be revised to present
       information and summari/e findings in a format that can be easily understood by non-
       technical audiences.  The 1'i/h/ic Report should be shorter, and it should contain clearer
       graphics as well as maps showing geographic trends.

   In summary, the SAB \\as impressed  by EPA's effort to de\ elop the draft ROE and strongly
urges that the EPA effort be continued with some refinements  The continually updated ROE
should pro\ ide the information and analysis necessary lo evaluate the status of environmental
protection of the United Slates. This information is essential for U.S. efforts to support
sustainable use of natural resources for future generations.
                                       Sincerelv.
2s
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            Di  William Gla/e. Chair
            EPA Science Advisory Board
                                                         Dr. Virginia Dale. Chair
                                                         Advisory Panel on EPA's Report
                                                         on the Environment
                                                         EPA Science Advisory Board
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        C Kevic\\ Drult
      S/| 1/200-1
                                               NOTICE
This report has been written as part of the activities of the EPA Science Achisory 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 balanced, expert assessment of scientific mailers related to the problems
facing the Agency. This report has not been reviewed for approval  by the Agency and.
hence, the contents of this report do not necessarily represent the v ievvs and policies of the
Environmental Protection Agency,  nor of other agencies in the Executive Branch of the
Federal government,  nor does mention of trade names or commercial products constitute a
recommendation for use.  Reports of the EPA Science Advisor.- Board are posted on the EPA
website at hltp.'/u vwv.epa.gov, 'sab.
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     URC Rcvic\\ Draft
     S/l 1/2DIM
                               l'.S. Eiivironineiital Protection Agency
                                      Science Advisory Board
                       Advisory Panel on EPA's Report on the Environment
 ?   CHAIR
 s
 •>   Dr. Virginia Dale. Corporate Fellow. Em ironmenlal Sciences Division. Oak Ridge National
l<>   Laboratory. Oak Ridge. TN
11
12
13   MEMBERS
14
15   Dr. Mark Bain. Director. Center for ihe Em iromnenl. Cornell Uni\ ersity. Ithaca. NY
if.
r   Dr. Philip Bromberg. Bonner Professor of Medicine. Department of Medicine. School of
is   Medicine. UNC Chapel Hill. Chapel Hill. NC

2i)   Dr. Timothy Buckley. Associate Professor. Environmental Health Sciences. Bloomberg School
21    of Public Health. Johns Hopkins University. Baltimore. MD

23   Dr. Joseph Biinnell. Public Health research Biologist. United Slates Department of the Interior.
24   United States Geological  Sur\ey. Reston. VA

2<<   Dr. Ann Marie Gebhart. Director. Drinking \\aler Program. Underwriters Laboratories.
2"   Northbrook. IL
2S
2-)   Dr. Joseph Helble. Professor and Department Head. Department of Chemical Engineering.
     University of Connecticut. Storrs. CT

     Dr. Arturo Keller. Associate Professor. Bren School  of Environmental Science and
     Management.  Unix ersity  of California. Santa Barbara. Santa Barbara. CA

     Dr. Charles Kolb. President and CEO. Aerodyne Research. Inc.. Billerica. VIA

     Dr. George Lambert, Associate Professor and Center Director.  Center for Child and
     Reproductive Emironmental Health. En\ironmental and Occupational Health Sciences Institute.
     Robert Wood Johnson Medical School/ University of Medicine and Dentistry of New Jersey.
•lo   Piscataway. NJ
•II
42   Mr. Norman  LeBlanc. Chief of Technical Senices. Hampton Roads Sanitation District.
43   Virginia Beach. VA
44
45   Dr. John McManus. Professor and Director. NCORE. RSMAS. University of Miami. Miami.
4i-   FL

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Dr. Maria Moraiuli. Assistan; Professor of Environmental Science and Occupational Health.
Department of Environmental Sciences. School of Public Health. University of Texas - Houston
Health Science Center. Houston. TX

Dr. Kathyrn Saterson. Research Scientist /Executive Director. Center for Environmental
Solutions. Dn ision of Em iron nental Science and Policy. Nicholas School of the Environment
and Earth Science. Duke University. Durham. NC

Dr. Peter Scheff. Professor. Emironmental and Occupational Health Sciences. School of Public
Health. University of Illinois ai. Chicago. Chicago. 11

Dr. Oswald Schmitz. Professor. Yale School of Forestry and Environmental Studies. Yale
University. Ne\\ Haven. CT

Dr. Mark Schwartz. Associate Professor. Department of Environmental Science and Policy.
College of Agriculture. Uim ersily of California. Da\ is. CA

Dr. Alan Steinman. Director. Annis Water Resources Institute. Grand Valley Slate University.
Muskegon. MI

Dr. Stephen Trombulak. Professor of Biology and Environmental Studies. Biology and
Environmental Studies. Middleburv College. Middlebury College. VT

Dr. Cynthia \V a trick. Assistant Professor. Management and Policy Sciences. School of Public
Health. Universitv of Texas Health Science Center Houston. Houston. TX
2S   SCIENCE ADVISORY BOARD STAFF
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4f.
      Dr. Thomas Armitnge. Designated Federal Officer. Washington, DC

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     QRC Reviev\ Drult
 2                                  TABLE OF CONTENTS

 4
 5    1.  Executive Summary	   ix
 6
 7    2.  Introduction	   1
 s
 •)    3.  Charge to the Review Panel	   2
in
n    4.  Review Process	   3
12
13    5.  Response to the Charge Questions 	   3
14
15       5.1  Response to Charge Question 1	   3
16
1"          A. Key Recommendations in Response to Charge Question 1  	   3
is
M          B. Specific Comments in Response to Charge Question 1	   5

21       5.2  Response to Charge Question 2	   8

23          A. Key Recommendations in Response to Charge Question 2  	   8
24
25          B. Specific Comments ill Response to Charge Question 2	  II
26
27       5.3  Response to Charge Question 3	  26
2H
29          A. Key Recommendations in Response to Charge Question 3  	  26
 o
 l          B. Specific Comments in Response to Charge Question 3	  29
 i
 3       5.4  Response to Charge Question 4 	  32
 4
 5          A. Key Recommendations in Response to Charge Question 4	  32
 6
 7          B. Specific Comments in Response to Charge Question 4 	  33

3->       5.5  Response to Charge Question 5	  34

4!          A. Key Recommendations in Response to Charge Question 5  	  34
42
43          B. Specific Comments in Response to Charge Question 5 	  35
44
45    6.  References	  37

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     QRC Review Dial!
     S/11/2004
 2   Appendix A:  Technical Corrections and Comments on the draft ROE
 3
 4   Appendix B:  Specific Comments Referring to the draft Public Repoit
38

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     ORC Review Dtul'l
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 2   I.     EXECUTIVE SUMMARY
 •*
 i      The Science Advisory Board (SAB) Panel on L:,PA"s Report on the Environment was charged
 5   with reviewing /•,"/>.A '.v Drafi Report on the f-~n\'ironmcnt 2003 (ROE).  The draft ROE was
 <'   developed by EPA lo describe what the Agency knows, and does not kno\\. about the current
 ?   state of the environment at the national  lex el and how the environment has changed as a result of
 x   human actions. The draft ROE is presented in l\vo \ olumes:  a detailed Tccliniail Document, and
 i»   a somewhat shorter more general Public Repori. The two volumes pose questions about the
lo   em ironment and human health on a national scale and provide answers to those questions in
11   cases where EPA has determined that scientifically sound indicators and high-quality data to
12   support them  are available.
n
I-i      EPA sought the SAIVs re\ iew of: the approach  and process used to develop the draft ROE;
is   the scientific and technical soundness of the indicators, data, and conclusions in the report; and
u<   the scale of indicator data used in the report.  FPA also requested advice from the SAB on ho\\
i ~   measurements of impacts on human health and ecological condition could be more effectively
i s   addressed, and ho\\ the presentation of information in the report could be enhanced
i'i   Specifically, the EPA gave the following fi\e charge questions to the SAB Panel:
2ti
21   Question 1
22   Please comment on the approaches, processes, or frameworks used in  describing the
2."   en\ ironmenla! status and trends and how to measure and  manage for environmental results.  Do
2-i   you ha\e any suggestions to enhance the scientific  analysis and presentation of the information'.'
25
2<<   Question 1
2"   Do the discussions of indicators in the Tcchnicu! /)uciiineni accurately portray the current state-
2K   of- trie-science'.'  Are the conclusions supported by  the scientific information pro\ ided given the
2i>   existing data gaps and limitations1'
 o
     Question 3
     Conventional Agency practice has been to measure and reduce emissions and subsequent
     exposure to pollutants.  Can you suggest how measurements for human health and ecological
     condition impacts resulting from environmental perturbation could be more effectively
     addressed'.'

     Question 4
     The draft ROE focuses on indicators at the national scale. Regional indicators are highlighted in
     a few case studies. How useful are national indicators in  presenting information on the quality of
•in   the environment? How much  consistency is necessary in indicator measurements and data
4t   quality across the country? Should more detailed regional data and indicators be accommodated
• 12   in a national oven iew of the environment, and how could these regional data be accommodated'.'

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Question 5
The Public Report is intended '.o summari/e the 'technical Document for a broad, non-technical
public audience.  Does (he rtihlic Report accurately and adequately reflect the technical content.
including the gaps and limitations, of the Technical Document''1

In this ad\ isory report, tile SAFJ provides specific recommendations and comments in response
lo each of these charge questions.

   The SAB finds that the ROH is a critically important document, providing the first national
assessment of the em ironment in a context of human and ecological health  The SAB notes that
there is an urgent need for this kind of assessment.  It can have an important impact on
improving the stale of the environment by synthesi/ing useful information from many sources.
This information  can be used by EPA. other federal and state agencies. Congress and state
legislatures, and academic and private sector organi/alions for the development of effective
environmental  policy and protection programs.  The SAB also notes that the ROE can provide
the public  with essential information about environmental status and trends and their relevance to
public health and ecological  condition. The SAB therefore encourages continued significant
effort in developing and impro\ing the ROE and belie\es that EPA is the appropriate agency to
lead this effort

   The SAB provides a number of recommendations  for improvements in future versions of the
ROE to make the document  more useful lo EPA and other intended audiences. The SAB finds
that EPA should:

    •  Allocate funds and stuff to ensure that the report is continued on a regular basis.  In
      order to sustain this important effort over the long term, the SAB recommends that the
      EPA  dedicate resources and a permanent team of staff to s> nlhesi/e appropriate
      indicators and data for the next report. The team should include statistical expertise, and
      should be assigned the ongoing tasks of pooling and anaK /ing data for the ROE and
      conducting more  anaK sis and synthesis than \\as included in the draft ROE

    •  Keep the ROE free  of conclusions about the impacts of specific policies or other
      government initiatives. It should be maintained as a Report on the Environment that
      re\iev\s the status and trends of en\ iron menial conditions in the United States

    •   Develop an expanded introduction to the ROE, defining the purposes of the
      document, describing the rationale behind the approach, and explaining the
      indicators and conceptual framework behind the structure.  The organi/alional focus
      of the draft ROE on questions and indicators is basically sound.  However, the draft ROE
      fails lo  communicate a consistent and clear purpose or to provide an overarching
      framework for the document. This deficiency has had wide ranging effects on the
      document, including  varied and inconsistent approaches lo indicator selection, and
      uneven treatment of indicator reliability.  The expanded introduction should include a
      discussion of ho\\ the indices and data presented in the report relate and merge into the
      overarching themes of interest in the document: human health and ecological condition.
      The expanded introduction should pro\ ide a better explanation of the criteria for selecting

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     URC Review Draft
     8/11/201)4

 l           ihe questions that are asked in the succeeding chapters, explain (he concept of an
 2           indicator, explain what indicators were selected and why they \\ere selected, and
            distinguish among different and expanded categories of data a\ailable for the selected
 4           indicators.  The SAB suggests that reasonable criteria for selecting indicators might
 5           include scientific defensibiliiy. qunnli(lability, transparency, and consistency.
 6
         •  Reorganize the report to: provide greater consistency among the air, water, and
 s           land chapters; address linkages between exposure and human health in the human
 9           health chapter; and organize the ecological condition chapter around synthesis
10           questions, with specific indicator data relocated to other chapters.  The chapter on
11           human health impacts of pollution should de\ ote greater attention to the linkages between
12           exposure and health effects.  Some environmentally linked health effects are \\ell
i?           established and should be presented as such without equivocation.  Other effects, which
14           are suspected but less well established, can also be discussed  However, cataloging all
15           causes of morbidity and mortality, most of \\hich  are not known or suspected of being
16           related to the types of environmental exposures described in the air. water, and land
17           chapters, seems less useful. The SAB commends the use of vignettes or case studies
is           focusing on specific pollutants (e.g.. lead).  The approach to assessing ecological health
1-)           should be  restructured to nune a\\ay from reporting on isolated indicators such as the
2"           extent of forest land. The approach should integrate indicators from across different
21           locations (e.g.. air. water, and land) to assess  different essential ecological attributes
22           (EEAs). and then integrate multiple EEAs to  assess health with respect to key ecological
23           conditions. Questions addressing ecological health such as  the status of biodnersity.
24           fisheries health and sustainabilily. and element cycling could be used as organi/ing
25           themes. Regional and local data should be used to convey an accurate picture of trends
2ci           and knowledge gaps.  In addition, the effect of ecoiogic changes on human disease (e.g..
27           Lyme disease. West Nile viral encephalitis) should be discussed.
28
29        •  Incorporate regional indicators into the report when they can provide insight on
 M           national conditions.  Much can be  inferred from  data a\ ailable at  local and regional
 I           scales.  National indicators can be built from  local and regional data and measures. Also.
 2           some environmental changes are best understood  by considering regional impacts (e.g..
 3           air quality)  Therefore, indicators in the next version of the ROF. should not be limited to
 4           those for \\ hich data are a\ ailable at the national level.
 5
 6        •  Strengthen the report by adding certain  key missing indicators and providing
 7           additional information about indicators that are currently included in the report.
 s           Future versions of the ROE should distinguish between emitted (primary) pollutants and
 <>           environmentally synlhesi/.ed (secondary-) pollutants and discuss the concept of secondary
40           pollutant precursors. Water quantity information  should be added  to future \ ersions of
41           the ROE.  Kull coverage of the h\ drologic cycle is needed to complete the assessment of
42           status and trends in w ater quality and other u ater-related aspects of the em ironment.
4?           Information about grounduater. large scale \\ator a\ ailability. and  human \\ater use and
44           demands are missing from the draft ROE. The water and land chapters of future reports
45           should contain indicators that address both  the extent and quality of different  land and
-ifi           \\ater ecosystem types. Contaminants in food and diet are also a critical component of

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    em iron men t as il relates to human health and should be included in future versions ofthe
    ROE.  EPA should also rethink the indicator gap and limitations approach presented in
    the draft ROC. The indicator gap and limitations sections ofthe draft ROE contain an
    assortment of qualifiers that either inappropriately discourage the reader from believing
    the data presented, or lead the reader to correctly conclude that the indicator is unsuitable
    as il is configured, Some \\aler indicators presented in the draft ROE. such as dissolved
    o\\gen. chlorophyll, \\ater clarity, and index of biotic integrity, \\ere not useful as
    de\ eloped in the report. The  report appropriately discourages readers from belie\ ing the
    data presented on these indicators.  As staled belo\\. future versions ofthe ROE should
    include indicator data relevant to global climate change. Future versions ofthe ROE
    should also identify useful indicators of either human or ecological health for which only
    regional data, or no data, are currently a\ailable.

•   include analyses and presentations of much greater statistical rigor. General lack of
    statistical analysis in the draft ROE seriously limits the presentation and interpretation of
    status and trend information.  Future versions of the ROE should incorporate much more
    rigorous statistical analyses of human health and ecological condition indicator dala in
    order to:  de\ elop informative syntheses and spatial  displays, identify  patterns, and depict
    trends.  Greater statistical rigor is also needed in the description of pollution sources and
    post-emission transformations and transport. In future versions ofthe ROE. EPA should
    not aggregate dala into national averages and trends when such aggregation leads to a
    loss of information.  Rather than  using the work summaries of others. EPA should
    conduct more in-depth data analyses and present summary data, ranges, measures, and
    trends. In addition. arb:trary  measures of condilions such as "good" or "poor" should not
    be used in future \ersions of the ROE unless these measures are the established norms in
    the indices used and  are \alid conclusions that compare indicators on a national scale.
    Uncertainties in dala and interpretation should also  be discussed.

•   Include indicator data relevant to global climate change. Omission of global climate
    change in relation to anthropogenic air pollution, and its health and ecologic implications.
    is a major defect in ihe draft ROE. Climate change is both a confounding and primary
    driver of the slate of the emironment. Therefore, lack of coverage of any aspect of
    climate change greatly hampers the presentation and interpretation of many  indicators
    and topics in the draft ROE.  Future versions of the ROE should recogni/.e that global
    climate change \\ill have first order impacts on  a \\ide range of em ironmental indicators.
    and through them on human health and environmental conditions  Indicators relaled to
    global warming, such as changing air and water temperature patterns, changing ice
    formation and thav\ing patterns, trends in global concentrations of primary climate
    change gases, trends in U.S. emissions of these gases, and trends in scattering and
    absorbing aerosol particle concentrations are very important and should be included in
    future ROE documents

•   Revise the draft ROE Public Report to include more graphics and make it user
    friendly.  The draft ROE 1'nhlic Report is a long but largely abstracted presentation of
    the draft ROE 'll'dinical Report.  The Public Report should be revised to present
    information and summari/e findings in a formal thai can be easily understood by non-

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       technical audiences. The I'nhlic Report should be shorter, and it should coniain clearer
       graphics as \vell as maps shoeing geographic trends

   III summary, the SAB was impressed by EPA's elTort to dexelop the draft ROE and strongly
urges that the EPA effort be continued with some refinements. The continually updated ROE
should pro\ ide the information and analysis necessary to e\ aluaie the status of em ironmental
protection of the United Stales thai will allow sustainable use of natural resources for future
generations.

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                 Review of EPA's Draft Report on the Environment 2003

                    An Advisory by the Science Advisory Board Panel
                          on EPA's Report on flie Environ men t
2.
INTRODUCTION
   This report transmits the advice of the U.S. Environmental Protection Agency (EPA) Science
Advisory Board (SAB) Panel en EPA's Draft Report on the Environment 2003 (ROE). The draft
ROE \vas developed by EPA to describe what the Agency knows, and does not know, about the
current slate of the environment at the national level and ho\\ the environment has changed as a
result of human actions. This analysis can inform the Agency about deficiencies in current
knowledge of environmental status and  trends.  Publication of the draft ROE was the first step in
EPA's  Environmental Indicator Initiative.  This is  a multi-Near process directed at developing
better indicators that EPA can use to measure and track the stale of the environment and to
support improved environmental decision-making at EPA and elsewhere  The draft ROE is
presented in  two volumes: a detailed Technical Document, and a somewhat shorter more general
Pnhlic  Report.  The two volumes pose questions about the em ironmeni and human health on a
national scale, and prov ide answers to ihose questions in cases where EPA has determined that
scientifically sound indicators and high-quality data to support them are av ailable.  EPA has
slated that it  does not intend to revise the current draft of the ROE. but has conducted a Science
Adv isory Board rev iew of the document in order to obtain adv ice  for use in dev eloping future
Reports on the Em ironmeni.

   In developing the draft ROE. EPA framed environmental quality issues by: I) identifying key
questions: 2) identifying an iniiial  set of indicators: and 3) rev lewing and selecting the indicators
and the supporting data to be included in the report. Historically.  EPA has used a set of
indicators to measure progress in reducing environmental  pollution through its major regulatory
programs. These traditional measures for air. water and land conditions are discussed in the first
three chapters of both the draft 'technical Document and I'nh/ic Report. EPA. together with its
Federal, slate, and tribal partners, is moving toward supplementing these traditional  measures
with indicators that provide a belter understanding  of status and trends in human health and
em ironmenlal condition.  Chapter Four of the Technical Document and the I'uhlic Report
presents key information on exposure to pollutants  and the status of human health that can be
used to dev elop environmental public health indicators. Chapter Fiv e of the Technical Document
and the 1'iihlic Report similarh  describes essential  attributes related to a synthetic v iew of
ecological condition. Chapter Six of the Public Repor; identifies key challenges in the
development and implementation of better indicators of human health and environmental status
and trends.

    The SAB Panel enthusiastically supports this effort.  It sees the draft ROE as an extremely
important document and comirends EPA for its foresight in taking such strong initiative to
dev elop the Report on the Environment. The SAB  encourages cominued significant effort in
dev eloping such reports and thus supports an  increase in national em ironmental analyses and
syntheses of environmental indicators   We recogni/e that many of the areas addressed in the
draft ROE are not part of EPA's responsibilities, but the Panel believ es thai EPA is the

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appropriate agency to lead this effort. Our comments below are quite lengthy, a reflection of the
Panel's view of the importance of this activity.  Our o\ erall response to the draft ROE is that it is
of critical national importance and must be continued and improved.

   We pro\ ide a number of recommendations for improvements in future versions of the ROE to
make the document more useful to EPA and other intended audiences.  The SAB recommends
that EPA reorgani/e the framework of the ROE to enhance the analysis and presentation of
information in the report The ROE should contain an opening chapter lhat clearly lays  out the
purpose and vision of the report and sets forth the criteria for selecting the indicators and
questions in the report. The ROE should contain important data and indicators thai are available
at local and regional scales, as well as analyses of greater statistical  rigor.  In addition. EPA
should develop a working conceptuali/alion of how different parts of the ROE can be integrated.
Health impacts resulting from environmental pollution should be addressed in Chapter Four
(Human Health) through a more rigorous and systematic consideration of linkages to exposure
Chapter Five (Ecological Condition) of the draft ROE should be de\ oled to synthesis of
information. Therefore, much of the information currently in Chapter Five should be moved into
other appropriate chapters.
3.
CHARGE TO THE REVIEW PANEL
   EPA sought the SAB's review of: the approach and process used to develop the draft ROE:
the scientific and technical soundness of the indicators, data, and conclusions in the report; and
the scale of indicator data used in the report.  EPA also requested ad\ ice from the SAB on how
measurements of impacts on human health and ecological condition could be more effectively
addressed, and how the presentation of information in the report could be enhanced.  The EPA
ga\ e the follow ing five charge questions to the SAB Panel.

Question 1
Please comment on the approaches, processes, or frameworks  used in  describing the
environmental status and (rends and how to measure and manage for environmental results  Do
you have any  suggestions to enhance the scientific analysis and presentation of the information'.'

Question 2
Do the discussions of indicators in  the Technical Document accurately portray the current state-
of- the-science? Are the conclusions supported by the scientific information provided given the
existing data gaps and limitations'.'

Question 3
Conventional  Agency practice has  been to measure and reduce emissions and subsequent
exposure to pollutants. Can you suggest how measurements for human health and ecological
condition impacts resulting from environmental perturbation could be more effectnely
addressed''

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The ROE also can provide the public with essential information about environmental status and
trends and their relevance to public health and ecological condition. That said, the SAB notes a
number of genera! and specific concerns and recommends that they be considered by the Agency
in the next iteration of the ROE.  Generally, the SAB finds that EPA has not applied a consistent
approach in the development of the draft ROE. In some sections the draft ROE is primarily a
report on the Nation's environment, but in a few places it appears to be  more of a report on
EPA's  environmental imtiali\ es.  For example: 1) in the draft ROE Technical Document, the
introduction on page xi says that the ROE should ensure EPA accountability to the public: 2)
page 5-3 of the draft ROE Technical Document introduces the synthesis chapter by talking about
EPA measuring outcomes, the fact that EPA seeks to protect air land and \\ater. EPA's statutory
authority, and the fact that EPA can monitor stressors; 3) the summary box on page i\ of the
draft ROE i'uhlic Report talks about EPA's role in protecting land: 4) page v of the draft ROE
j'ltblic  Report talks about EPA's mission: and 5) page vii of the draft ROE hihlic Report
indicates that  the ROE \\ill "enable EPA to belter manage for results".  The SAB encourages
EPA to clearly make the next iteration of the ROE an overall report on the environment and not a
"report card"  for EPA. and recommends that this perspective be set forth clearly at the beginning
of the document.

   As an oxerall report on the environment, the next ROE should not only address  indicators that
are a\ ailahle at the national scale, bul also consider and include regional or local indicators
where appropriate.  Whenever possible, an explanation of the context, current status,  and trends
10 dale for each indicator should be pun ided and supporting data should be included  or
referenced, as appropriate. EPA should avoid reporting indicator status or indicator trends
without linkages to supporting data.

   In order to sustain this important effort oxer the long term, the SAB  recommends that the
EPA dedicate resources and a permanent  team of staff to identify appropriate indicators and data
for the  next report.  The team should include slatistical expertise, and should be assigned the
ongoing tasks of pooling and analy/ing data for the ROE and conducting more analysis and
synthesis than \\as included in the current ROE.

   SAB recommends that EPA reorgani/e the frameuork of the ROE to enhance the  analysis
and presentation of the information contained in the report. This should include:

    1   An initial chapter that presents the purpose and \ ision of the report and clearly articulates
       the criteria for selecting the indicators and questions that are included in the report. In
       the initial chapter EPA should also clarify the meaning of "national-level indicator."
       Quite  a large amount of data in  the draft ROE appears to be derived from state sources.
       and it  is not clear whether EPA  requires data for the entire United States fora national-
       lex el indicator.  EPA should strongh  consider using data sets that are not national in
       scope.  The opening chapter also should indicate that the report is not intended to provide
       an assessment ofhow em ironmental regulation or policies have led to current
       environmental conditions

   2.  A clearer indication and discussion of why some indicators and  data sets were included  in
       the report and others \\ere not. and a broader discussion of data gaps.  It is very important

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  i           lo lisl the data gaps, and the draft ROE does so lo a certain extent.  Ho\\e\ er. the
  2           definition of data gaps .n the draft ROE is too reslncthe because ihe gaps discussed in
             the report are only  those reflected by the known indicators.. The listing of data gaps
  4           should also include ind.calors or linkages for \\hich regional or national data may not
  5           exist. Appendix B of the draft ROE Tedmictil Document should be expanded lo include
  f>           a better explanation of why indicators and data sets were selected, or not selected, for use
  7           in the draft ROE. The sources of the data presented in the ROE must be specified, and
  x           criteria  used for excluding as well as including data also must be explicitly defined.  The
  9           SAB notes that it would be \ aluable to include questions, \\hich cannot be answered wilh
in           currently available indicators as a means to identify potential programmatic gaps.
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12       3.   ROE chapters  on air. water, and land that focus on current conditions, and an ecological
13           condition chapter that it. a synthesis of information addressing the o\ erall ecological
14           health of the United States. Much of the information currently  included in the ecological
15           condition chapter should be moved lo the water or land chapters (Chapters 2 and 3
if'           respectively).
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is       4.   The report should contain an index. Without an index, the draft ROE has limited
l 9           usefulness as a reference \\ ork.
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21       5.   Indicators related to global warming.  Apart from one or two brief sentences in each of
22           se\eral chapters, the iss.ie of global \\arming (and its rele\a:it impacts on the
23           environment and humar health in the United States) is missing from the draft ROE.
24           Climate change is an issue that applies to all chapters of the draft ROE.  The SAB notes
25           that indicators related to global warming, such as changing air and water temperature
2f.           patterns, sea le\ el rise a.ul carbon dioxide levels, are very important indicators
27           inextricably linked to human health and ecological  condition. The SAB therefore
2s           strongly recommends that these indicators be included in  the ROE.  In addition, more
29           examples of the use of indicators to illustrate ecological biological, and biochemical
             principles that directly apply  to the en\ ironmem should be included in the ROE

      B. Specific Comments in Response to Charge Question 1

      Introduction to the draft ROE

        The discussion of purposes and approach presented in the draft ROE introduction is not well
      developed. The introductory chapter of the report should pro\ ide an overall framework for the
      report  by defining what the en\ ironment is. what the report addresses, and what issues are not
      considered.  Future ROE versions should therefore start with a clear and concise introductory
411    statement to intended audiences telling them why they should care about the state of the
41    environment, and why the  ROE is an important document lo  read. This statement should invoke
42    a fundamental obligation to maintain the planet's habitabilily for future generations, and indicate
43    why clean air. clean water, product!\ e land, viable ecosystems, and a health) population are
44    critical to achieving this goal.  The purpose of the ROE should also be clearly slated in the first
45    chapter using an appropriate analogy that will  be meaningful to the general population as well as
46    policy  makers and environmental professionals.  One possible analog)  is a "report card' on the

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status and trends of environmental quality in the United Stales and its effect on the health of our
citi/.ens and on the condition of critical ecosystems.  For example, the ROE should provide
indicators of environmental health lhat are analogous to indicators of human health, such as
environmental health equivalent to: a health) young human, a likely candidate for a heart attack.
or even a post-cardiac patient.  The SAB does not. however, advocate that the ROE become, in
any way. a report card on EPA's role as an em ironmental regulatory and research agency

   The SAB recommends that the ROE initial chapter present an expanded introduction that
should sen e as a road map for  all readers of the report. It should include a discussion of ho\\ the
indices and data  presented in the report derive from information presented in the air. water, and
land chapters and build towards what the SAB considers to be the overarching themes of interest
in the ROE: human health and ecological condition (currently Chapters Four and Five). The
draft ROE does not clearly present the criteria used to select the indicators that \\ere included in
the report.  It  is unclear, for example, whether the indicators in the draft ROE are defined as
measures that can track environmental  conditions over lime, measures lhat reflect conditions at
one point in time, or both.  The expanded introduction should serve as the place to better explain
the criteria for selecting the questions that are asked in the succeeding chapters, lo define the
concept of using indicators to answer those questions, and to distinguish among different (and
expanded) categories of data available  for the selected indicators. The SAB encourages EPA to
first define the critical questions lo be ans\\ered and then find the indicators lo answer those
questions; il is important to not let the availability of data/indicators drive the questions.  The
SAB suggests that  reasonable criteria for selecting indicators should first include whether the
indicator \\ill reveal an environmental condition that will help answer a specific ROE question.
The indicator should also be scientifically defensible, quantifiable, transparent, and consistent in
application over lime. Readers of Ihe revised first chapter should be able to clearly see that  the
ROE \\as developed lo serve as a report on the status of the environment in the United Stales
with respect to both human  health and ecological condition (or ecological "health") and lo
understand the characteristics that are used in the report card lo assess health and ecological
condition. The reader should be able lo understand that ihe ROE is intended to be an on-going
effort lhat will help the American people see ho\\ and where progress is being made toward
better ecological conditions and human health as it relates lo ihose conditions, as \\ell as areas
\\here ne\\ or additional efforts may be needed

   The SAB also recommends  thai the introduction be explicit about what is outside the scope of
the ROE.  While acknowledging thai air. \\aier and biological resources of ihe United States
Mow across national boundaries, the report should focus  on the ecological condition of the
United Slates. Comparisons between conditions in the United Stales and those in other nations
or regions should be included \\hen they provide the necessary context for understanding
conditions in  the United Stales: for example. Chapter 4 provides comparisons of a number of
human health indicators in the Iiiited Stales \\ilh oilier nations.  Similar comparisons would be
helpful in chapters on air. land  and water. The ROE should not attempt to link current
environmental and health conditions and trends to specific policies or programs, except in cases
where a policy or program is the obv ions and undisputed explanation for a significant trend  or
status  The ROE should not suggest policy and program solutions to the problems described

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        The first three chapters of the current draft ROE should focus on air. water, and land
 4     conditions and trends as they rotate to human health and ecosystems. The air chapter should
 5     make clear the differences between primary air pollutants generated from emission sources and
 6    secondary and tertiary air pollutants that are synihesi/.ed in the atmosphere from directly emitted
      precursors  The primary sources of air pollution and the processes of conversion, accumulation.
 H     dispersion, transport, and deposition (including acid ram)  should be outlined. The cross-chapter
 l>     linkage between atmospheric sources of pollutants addressed in the air chapter and lake
ID     acidification effects addressed in the chapter on water should be discussed and referenced in the
i I     chapter on ecological condition.  It would also be useful to include relevant indicators from  other
12     chapters on the indicator list in the air chapter. The chapter on water should include an overview
1i     of general \\ater budget and hydrologic principles.  The land chapter should be reformulated and
14     expanded to better reflect symmetry with the air and \\ater chapters.  The SAB recommends that
15     the land chapter be focused on land use.  and that the chapter's introduction explain this focus.
u>     This chapter should pro\ ide information about developed land areas (including areas with high
i?     industrial and  waste impacts), as \\ell as non-developed land. The air. \\ater. and land chapters
is     should all be retitled uithoul  qualifiers because the current titles do not accurately reflect
h»     information in the chapters.  For example, the current title of Chapter Three. "Better Protected
2n     Land." \\hile reflecting EPA  Administrator Whitman's motivating interest, is inherently
21     imprecise  The SAB suggests that the title. "Land Use" \\ould be preferable. Chapters One and
22     Two should be retilled "Air" and "Water" respectively.
2.1
      Chapters -1-5

        Chapters Four and Five of the ROE should continue to focus on environmental effects on
      human health  and ecological  condition, respectively, in future editions. Howe\er. the ecological
      condition chapter should be reformulated and  organi/.ed around ke\ questions such as: "\\hat is
      the status of biodiversity?", "wial is the status ofglobal \\arming trends'.'", and "what is  the
      status of element cycling?" This reformulation of the ecological condition chapter would require
      that EPA mo\  e mam of the questions and indicators in the present chapter to the air. water, and
      land chapters  Questions about the extent of terrestrial communities should be placed in  the
      chapter on land. Similarly, questions and indicators related to the extent of aquatic communities
 4     should be moved into the chapter on water.
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 (•>     Other recommendations

        The current ROE is devoid of statistical analysis. The  report can be greatly enhanced by the
      use of appropriate statistical procedures  for assessing changes oxer lime (e.g.. longitudinal
40     analysis or lime series analysis;-.  Averaging of data o\ er time or across a group of more-or-less
41     simultaneous observations at different loci \\as used to ex  aluate and report trends in  the draft
42     ROE.  This is  a useful xxay  of making large data sets manageable and presentable. However, a
4?     great deal of information is necessarily lost. For example, annually ax eraged o/one  lex els are
44     much loxxer than the averages restricted  to the summer months; daily data over a year are not
45     normally distributed, so arithmetic averages alone may be misleading. If the primary- data are
46     normally distributed, standard deviation and standard error of the mean can be reported.  For
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non-normally distributed data, means, medians, and ranges might be reported.  Time trends
(vectors) are subject to \arious forms of error.  Vectors derived from t\\o points are particularly
suspect and non-linear relations are not adequately expressed \\ ith slope and intercept.  When
trends are reported in the ROE. slopes of linear relations should be assessed for significance of
llie difference from x.ero (i.e.. no change o\ er lime) and for the 111 ofthe data points to the trend.
The SAB notes that individual data points in some data sets used for trend analysis in the draft
ROE max themselves  represent the mean of multiple observations and therefore incorporate
some quantifiable uncertainly.  Changes in measurement methods, changes in a population base.
and changes in a category assignment can also lead to errors of representation and interpretation.
Methods such as meta-analyses. use of rolling  averages, and locally weighted scatter plot
smoothing functions (LOWESS) should be applied to evaluale trends. The SAB also notes that
the draft  ROE does not explicitly address the area of uncertainly.  There are main  approaches to
addressing uncertainty, ranging from quantitative (e.g.. Monte Carlo analysis and sensitivity
analysis) to qualitative (e.g.. data gaps). The EPA should explicitly address the area of
uncertainty in future Reports on the Environment.

   The SAB recommends improvements in the draft ROE to enhance presentation ofthe
information. Some ofthe data presented in plots appear to be  grouped arbitrarily  Where
feasible,  plots should show  all ofthe available data, and additional captions or appendices are
required  in the Technical Document to indicate \\hat is  being plotted. For example, in Exhibit 1-
I of the air chapter in  the Technical Document . the methods used to aggregate the data are not
clearly presented.  In this exhibit, primary and  secondary air pollutants are lumped together, and
the implied emissions  of secondary pollutants are not meaningful.  The exhibits included in the
ROE should provide information indicating the baseline from  which changes or trends are
assessed, the number of monitoring sites, and oilier relevant information  When possible, the use
ofa common baseline for the exhibits would be helpful (e.g. Exhibits 1-1: 1970. Exhibit 1-4:
19X8. and Exhibit  1-6: 19X2 all use the same data)

5.2    Ouestion 2: Do the discussions ol indicators in /he Technical Document accurately
portray ihe curreni stule-of- the-science''  Are  the conclusions supported hy the scientific
           provide J gt ven  the existing data gaps and limitations'.'
A.  Key Recommendations Response to Charge Question 2

   The SAB provides the following key recommendations regarding indicators and conclusions
in the Air. Water, and Land chapters ofthe draft ROE.

Chapter One "Cleaner Air"

    I.  As previously noted, it is important to clearly distinguish between primary emissions and
       secondary air pollutants, particularly for "criteria pollutants".

    2.  Emission trend plots should clearly slate whether ihey are presenting direct primary
       emission data or precursor emission data

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    3.  Plots of decreases in "total national emissions of the six criteria pollutants" ha\e little
       meaning because no clear distinction is made between primary pollutants that are emitted
       directly into the atmosphere and secondary pollutants that are synihesi/.ed in the
       atmosphere from precursor species. In the United States, total airborne concentrations of
       only two (SO:, and Pb) of the six criteria air pollutants are dominated by primary
       emissions  Of the remaining four criteria air pollutants: o/one (O?) concentrations are
       almost completely dete'mined by secondary production; while the remaining three. NO:.
       C'O. and PV1. have very substantial secondary  sources  Thus, there is no scientifically
       meaningful way to combine the "emissions" of criteria air pollutants. It should be noted
       that concentrations of pollutants in specific regions of the  atmosphere can be impacted
       une\enly by various sources  For instance, ground lexel C'O le\els during urban rush
       hours are usually dominated by \ehicle emissions, while C'O concentrations in the free
       troposphere oxer rural areas will often contain a large amount of C'O produced from the
       in-situ photochemical oxidation of organic compounds.

   4.   Statements in Exhibit 1 2 of the draft ROE indicating that there  are "no category 1  or 2
       indicators" are misleading because many environmental issues ha\e intrinsic
       characteristics that make national indicators either inaccessible or irrelevant. It is the
       opinion of the SAB thai such statements may be misinterpreted  as lack of knowledge.
       when in fact indicators of differing temporal or spatial scales, other assessment
       documents, and  primary literature provide useful information. The SAB notes that this
       recommendation is also pertinent to Charge Question 4.

   5.   Time trend plots in the ROE should extend as  far back  in time as practical, be as current
       as possible, use linear a\es. and a\oid starting on anomalous years (e.g.. I^HH for o/one)
       if percentage changes are presented.

   6.   Airborne toxics  are an increasingly important  issue that should be included in the ROE.
       The SAB recommends (hat data from the National Air Toxics Assessment and new
       monitoring programs be included in future versions of the ROE.

   7.   Indoor air is a primary determinant of human exposure (and therefore, health effects) for
       many air pollutants.  Because there are no national scale data to assess indoor air
       pollutant le\els (with the exception of radon),  the SAB recommends that future \ersions
       of the ROE provide information on the relationship between outdoor and indoor
       concentrations for key pollutants  Future reports should use the a\ailable primary
       literature to identify  ke\ indoor pollutants and assess their levels.

   H.   The SAB notes that climate change will have a fundamental impact on future air quality.
       as well as on a wide range of other environmental indicators.  The SAB therefore finds
       the presentation and discussion of trends of air quality indicators to be scientifically
       indefensible in the absence of an assessment of climate change.  As noted previously, the
       topic of climate  change must be included in the next  ROE.

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Chapter Two "Purer Water"

    \.  The ROE water chapter should contain a much more detailed discussion of trends and
       status in national and regional water demand, supply, and quality.

    2.  The ROE water chapter should also prov ide a temporal and spatial perspective for the
       indicators presented in the draft ROE. In addition, regional analysis of water indicators is
       needed to understand national conditions.  Regional stains and trends should be reported
       for additional areas of the United Stales where data sets are available.

    3.   A more consistent and complele description of ihe methodology used lo colled data and
       analy/e indicators in the water chapter is also needed. In particular, a more complete
       description of Ihe limeframe for dala  collection and of the derivation of Ihe "good."
       "fair." and "poor" descriptors  is needed.

    4.  The SAB notes  that  some of the criteria and benchmarks used in the water chapter reflect
       outdated science.  The National Water Quality Assessment and sediment concentration
       dala in the draft ROE should be compared  lo appropriate target criteria in order to reflect
       levels of concern, nol simply  ihe presence  or absence of chemicals of concern. It may in
       faci be more appropriate lo use regional criteria and benchmarks lo analy/e some of the
       water dala.

    5.  The SAB recommends that indicators be developed lo report the following information:
       groundw aler quantity and quality: the effects of global climate change on sea water
       chemistry, sea level, and stream How: changes in water  temperature: changes in tolal
       dissolved solids and salinity over time due lo human  activities, quality of irrigation water
       (eg salinity, nutrients, and toxics); and detection of emerging  pollutants in waler
       supplies across ihe United Slates.

   The SAB notes  thai  important available national dala are  omitted from Chapter Two of Ihe
draft ROE. and recommends thai the following information be included in future reports:
drinking water information  regarding  types and severity of violations,  sources of contaminants.
and health effects,  fish advisory information  regarding types and severity of violations: Clean
Waler Act section 3()3(d) list of impaired walers: and National Pollution Discharge Elimination
System information regarding trends in pollutant loads and toxicity.

Chapter Three (Hetter Protected Land)

    I.  The SAB recommends that future versions of Chapter Five (Ecological Condition) of ihe
       ROE be devoted lo synthesis of information found in the air. water, and land chapters.
       Much of ihe information in Chapter Five of ihe draft  ROE should therefore be moved
       into fuliire land  chapters (or waler chapters if related to waler).  For example, information
       on extent and management  of forest area, forest age class, population representation of
       forest species, and soil compaction should  be moved  from Chapter Five to Chapter Three
       There arc also slark  differences in ihe current ROE between the land chapter and the  air
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       and water chapters. The nature of the questions about the condition of land should
       parallel that presented in the air and water chapters.

    2.  The SAB recommends that a broader range of indicators be used in future land chapters
       of the ROE.  Indicators such as extent of roads should be used to provide information
       about  habitat fragmentation, human use of land, and fragmentation of ecosystem types
       Other indicators such as socioeconomic distribution of human population in relation to
       land use and communilv composition of animal and plant species (biodiversity) should
       also be reported in Chapter Three.

    3.  EPA should consider using a greater number of ecosystem lypes than are currently
       described in Chapter Three of the draft ROE. Using only the aggregated measures of
       ecosystem lypes assessed in the draft ROE (e.g.. forests, grasslands, croplands, etc.) does
       not provide important insight about region-specific ecosystem lypes such as
       endangerment of tall grass prairie in the Midwest.  For this reason, while the SAB
       acknowledges that the ROE will primarily  report indicators developed by others, it is
       recommended that EPA not simply adopt the aggregated ecosystem types presented in the
       Hein/ Foundation's excellent report on the State of the Nations  Ecosystems.  EPA is
       encouraged to develop the mosl useful taxonomy of ecosystem types for answering the
       ROE-specific questions, and then use original data sources for appropriate indicators

    4.  It is important to clarify differences between  indicator gaps and limitations associated
       with the inability to answer specific questions, and the gaps and limitations related to data
       availability and quality needed to complete regional and national assessments. It is
       inappropriate to state that indicators do not exist when in fact, the ROE usually means
       that sufficient representative regional data are unav aitable to calculate national indicators.
       in cases where indicators to answer questions truly do not exist, the ROE should indicate
       the scale of reference (eg. there are no national indicators, or no regional indicators, or
       no local indicators).

    5.  It is important to provide uncertainty estimates  for indicators in  the ROE when this is
       possible.  The SAB notes that many indicators can be  derived from multiple data sources
       that provide varying estimates of condition. EPA should use such information
       strategically by estimating confidence limits for the indicators.

   The SAB recommends that EPA rethink the indicator gap and limitations (IGL) approach
presented in all chapters of the draft ROE  In the current draft of the ROE. the IGL sections
contain an assortment of qualifiers that often inappropriately discourage the reader from
believing the data presented.  The SAB feels that this is largely a result of poor definition of the
IGL section, and an apparent need to include information in the IGL section for each indicator.
or the selection of an inappropr ale indicator or measure for that indicator. This is discussed
below in more detail

B. Specific Comments in Response to Charge Question 2

Outdoor air - criteria pollutant*

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 2       Exhibit 1.1 plots "aggregated criteria pollutant emissions", but there is no indication of what
 3   data are actually aggregated. As noted previously in our response to the charge question,  an
 4   aggregation of data across dissimilar pollutants is not \ery meaningful  As previously noted, a
 5   clear presentation of the difference between primary and secondary air pollutants is required
 <>   The critical precursors for secondary criteria pollutant formation should also be clearly
 i   identified  Such clarification will  emphasi/e the importance of NOX and volatile organic
 s   compound (VOC) emissions data  for O; formation,  and the impact of SO:. NOX. and VOC
 l>   emissions on paniculate matter (PM) formation
Hi
11      Although the current set of questions in Exhibit 1.2 addressing criteria air pollutants are valid
12   and  meaningful, additional important questions should be asked in future reports.  For example.
13   questions should be included such as: 1) What are the important sub-classifications of PM>.?
14   (ulirafines. organic carbon, black carbon, toxic metals, etc.) in terms of health, ecosystem and
15   climate impacts, and what data are available on primary emissions and/or secondary precursor
u>   pollutants'' 2) What photochemically generated oxidi/ed organics (e.g. aldehydes, kelones.
r   organic acids, organic nitrates. perox\organic  nitrates. DMSO. DMSOj. etc.) or inorganics (e.g.
is   HONO. HNO;.. etc.) may have significant potential human health impacts, and what data  are
I1'   a\ ailable on their atmospheric concentration'*

21   Outdoor air - air toxic*

23      Air loxics are important pollutants, and EPA is to be commended for including them in the
24   draft ROE There are no national  data available for most air loxics. beyond data for some VOCs
25   like ben/one, but future reports on the em ironment should identify and track recent efforts to
2(>   begin collecting these data. The National Air Toxics Assessment (NATA) estimates of ambient
2~   air loxics concentrations can be used to pro\ ide indicators for the ROE. These data sets are
2s   largely based on models, and therefore may not satisfy criteria for category 1 or 2 indicators.
2<>   However. NATA estimates are useful because they are national in scope and they pro\ ide a
 o   means for assessing aggregate exposure and risk.  The draft ROE includes ben/.ene in results for
 l   (>5 sites from IW4 to 2000 (Exhibit 1-14).  The SAB recommends that EPA expand this analysis
 2   to include other air toxics measured at these sites. EPA should also consider including other
 3   sites where trend data are available for extensive periods of time in areas known to have
 4   significant emissions (e.g.. Houston). These dala might be presented by source type (mobile
 5   source, area sources, etc.). Care should taken  to avoid ob\ IOLIS errors when presenting
 ('   concentrations information.  The SAB notes, for example, thai ben/ene is not a criteria pollutant
     so thai the indication of a National Ambient Air Quality  Standard (NAAQS) in  Exhibit l-l
 s   should be removed. The SAB encourages EPA to consider presenting mercury deposition dala
 i>   from the National Acid Deposition Program (NADP) network either in the air or land chapters of
4n   future reports, and notes that the em ironmental databases of other agencies may provide useful
41   information in this regard. It is also noted that main air  pollutants (e.g . PM. air toxics) are
42   emitted by indoor sources, and that these source emissions tend to dominate exposures so that
43   current status and trends relevant to health are not are not captured by outdoor air measurements.
44   EPA should identify these data gaps and  limitations. SAB also notes that, although it is
45   discussed in the air chapter of the  draft ROE. lead has little rele\ ance as an  air indicator linked to
-K.   human health since most of the lead exposure  and associated human health  effects  are drixen by

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ingestion of contaminated dust, soil and. or paint. The atmospheric sources oflead are now very
limited.

Acid deposition

   Although the discussion of acid deposition in the draft ROE is basically sound. Exhibits 1-22
and 1-23 are difficult to interpret and reproduced at too small a scale.  A better presentation
graphic should be developed for future reports.  The "no category I  or 2 indicators identified"
notation for the third acid deposition question should be eliminated and replaced with a reference
to the re-lex ant National Acid Precipitation Assessment Program (NAPAP) assessment
documents.

Indoor uir quality

   Indoor air is a major microem ironment that can contribute significantly to inhalation
exposures, frequently exceeding the contributions from outdoor air inhalation.  Indoor air quality
is insufficiently treated in the draft ROE. When inhalation exposures  to airborne contaminants
are dominated by outdoor source contributions (e.g.. o/one. sulfur dioxide), ambient
concentrations are a reasonable indicator of exposure and potential health effects.  Conversely.
for mam pollutants (e.g.. PM. NOX. CO. HONO. toluene, chloroform, formaldehyde) exposure
results from a combination of both indoor and outdoor sources.  For many such pollutants.
ambient measurements prox ide a poor indicator for both exposure and health impact.  For some
pollutants  (eg. PM. formaldehyde) indoor lex els often significantly exceed outdoor lex els and
therefore dominate exposure.  Some discussion and literature citations about major sources of
important  indoor air pollutants (NOj. HONO. HhCO. CHCh. and others) should be included in
future reports. In addition, the question. "Is ambient air pollution an adequate surrogate for
human exposure'.'"" should be added to the list in Exhibit  1-2 and addressed in future report
versions.  The "no category I or 2 indicators identified" notation for the current indoor air
quality question three should be replaced \\ith references to relevant archival rex iews or primary
literature.
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              eric ozone
   The presentation in the draft ROE on stratospheric o/one depletion is sound. Exhibit 1-28
displaying trends in U.S. indiisirial production of o/one depleting chemicals contains only
chlorine compounds and should be expanded to include halon 1 2. halon 1 3. and methyl bromide
since, on a molar basis, bromine released in the atmosphere is about fifty times more effective
than chlorine in catalytically destroying o/one.  The captions for Exhibits  1-27 and 1-29 should
note that they include both chlorinated and brominated compounds, suitably \\eighted.  The "no
category j or 2 indicators identified" notation for the third and fourth stratospheric o/one
question should be eliminated and replaced \\ith a reference to the rele\ant World
Meteorological Organi/ation (WMO) and National Aeronautics and Space Administration
(NASA) assessment document;; or primary literature references

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 i    Climate change

 3       As we have stressed previously, climate change will almost certainly have a fundamental
 4    impact on future air quality (and vice versa). Climate change also has the potential to drive
 5    major changes in human health and ecosystem v lability. Thus, scientific relevance requires that
 <••    a significant discussion of climate change issues and indicators be included in future  versions of
     the ROE.  The SAB recommends thai  future reports on the environment address air-related
 s    climate change questions such as: 1) What are the trends in global concentrations of primary
 <>    forcing greenhouse gases (CO:. CH4. N:0. CFCs. PFCs. SFr,)'' 2) What are the trends in U.S.
     emissions of primary  forcing greenhouse gases'.'  3) What are the trends in tropospheric o/one
     over North America'' 4) What are the trends in scattering aerosol particles over North America'.'
12    5) What are the trends in absorbing aerosol particles over North America'.' 6) What are the
13    trends in U.S. emissions of primary fine particles'.' 7) What are the trends in the U.S. emissions
ii    of secondary aerosol  particle gaseous precursors'.'
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i (•    Atmospheric particulate matter (PM)

is       The SAB recommends thai future versions of the ROE continue to contain information on
i"    atmospheric paniculate matter. Paniculate mailer is a very complex mixture of suspended
20    particles of varying si/e. shape, and chemical composition. It has taken years of research to
2!    develop and apply the instrumentation required to dissect these complexities and the  work is
     ongoing. The PM standards have always been mass-based although such an approach affords
     greater "weight" to the larger particles that may  be less likely to be penetrate deep into the lungs.
24    PM in  ambient air is a secondary pollutant in large measure.   It was thought that a PMm NAAQS
25    of 150 micrograms cubic meter (24 hour av erage) furnished adequate health protection,  but this
2f>    turned  out not to be true, and EPA has now given more "weight" to smaller particles  with a
2"    PM: 5NAAQS of 65  microgramsxubic meter (24 hour average). Even this newer standard
2s    neglects smaller particles (< 0.1  micrometer), which contribute so little to mass that they are
2"    quantified as number of particles per cubic centimeter. The precise mechanisms by which
 0    inhaled ambient air PM causes morbidity and mortality are still not clear. However,  intensive
 I    research effort has been underway for several years and has produced support for several
 2    hypotheses. Hypotheses link effects to soluble metal  compounds - notably /inc. carbonaceous
 "    diesel exhaust particles (DEP) and absorbed semi-v olalile organic compounds, ultra-fine
 i    particles, and coarser particles with endotoxin-like activity. In spite of the absence of well-
 5    defined causal mechanisms and uncertainty as to the precise identity of the PM species
 !'    responsible, the consistency and coherence of the observed associations has justified  the
 7    imposition of more rigorous NAAQS for PM  EPA supports  a PM monitoring and speciation
 s    network but the network requires continual upgrading The SAB recommends that future reports
 "    contain data on trends in PM particle si/e in different  regions, trends in PM particle composition.
40    and trends in ultra-line particle concentrations, where such data are available, to provide a
41    broader picture of the distribution and trends in PM concentrations in this country.
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43    Atmospheric ozone
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4c>    atmospheric o/one. O/one formation requires photochemical energy plus NON and organic
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compounds. The NON arises from NO (and NOj) emitted from fuel combustion.  Organic
compounds also are released by fuel processing and fuel combustion: some organics such as
terpenes are natural emissions from vegetation. Despite developments in understanding of this
chemistry ov er the past several decades, the possible role of other o\y-organic compounds may
have been underestimated and o/one pollution continues to pose health problems - even in the
Los Angeles area, despite agererally impressive reduction in its o/.one levels since the 1970s in
the face of increasing human populations and vehicular traffic.  Other areas (e.g.. Atlanta.
Houston, the Northeast megalo )olis. Raleigh) hav e nol fared as well.

Water budget and regional water quantity/quality information

   Although the overall presentation of the stale of the nation's water resources is very useful.
the SAB recommends that additional information be incorporated into the discussion of
indicators in future reports.  The water chapter should provide a belter description of the water
budget for the  United States (based on recently released U.S. Geological Survey data) with a
discussion of trends.  The limited presentation of information on water quantity is a weakness of
the draft ROE.  It is also extremely important to include a discussion of regional water quantity
and quality in areas like California. Arizona, and Florida where this is a significant problem,  as
well as in other areas where water is an important issue  The SAB notes that even in areas where
water is apparently plentiful, such as the Great Lakes,  water supply issues are attracting political
and environmental attention (U5GS. 2004).  Depletion of aquifers in the State of Michigan is
leading to conflict resolution legislation (Michigan Department of Environmental Quality. 2004).
An indicator that measures or tracks trends in inierbasin transfers of water would be useful in
assessing the condition  of water quantity.  The general presentation in the draft ROE of the
nation's "average" water supply and quality is not particularly useful and potentially misleading
since it does not prov ide adequate information about regions of the United States where water
quantity and quality are becoming increasingly critical issues.

Temporal/spatial information about water indicators

   The SAB finds thai Ihere is a need to provide a more complete temporal  and spatial view of
the water indicators in the ROE.  Wherever possible, trends in water quality indicators should be
included in the report with spatial representation of the indicators (i.e.. on a map. preferably by
watersheds rather than political or administrative regions). Areas where the issues are
particularly critical should be mentioned in the text.  For example, the information on coastal
waters is presented mostly in pie charts. These charts  are not sufficiently  informative to
understand areas that are under stress.  By  prov iding temporal and spatial detail it will be easier
to make the links to human health and ecological condition  In many cases, a regional analysis
should be conducted and discussed before national analyses are presented.  Regional analyses
may then be integrated to produce a national indicator, if appropriate. The local information
should be presented along with the regional and/or national indicators.

   The SAB notes that coverage in the draft ROE is uneven with regard to available regional
information. For example, in the draft ROE there is a  heavy  reliance on information provided by
EPA's EMAP  Mid-Atlantic program, leaving out of the analysis information available from
other major regional studies on the condition of coastal waters (e.g.. Gulf of Mexico. Pacific
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 l    Coast) generated by the National Oceanic and Atmospheric Administration (NOAA) and other
 2    agencies. The absence of "easih "available indicator data should not be a constraint in providing
 3    a more complete picture.  A meta-anah sis approach should be considered to bring together these
 -i    \ arious datasels to present an integral!ve evaluation.
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 <>    Methodologies used to collect data and prepare water indicators
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 H       The SAB  finds lhal (here is a need to be more consistent and complete in the description of
 l>    the methodologies used in the draft ROE to collect data and prepare indicators. For example, in
lo    several cases, the dale of the studies supporting static indicators was not included.  For a number
11    of TN. TP and eutrophication indicators, the criteria used to classify the data into
12    "Good Fair Poor" are not described. In other instances, the benchmarks or criteria used for the
13    indicators reflect outdated scientific interpretation. The wetland indicators in the draft ROE are
i-i    generally out of date. Several \\ebsiles. listed in Appendix A. provide additional information
15    about standardi/.ed protocols  for measuring the status and trends of Great  Lakes coastal wetlands.
if-    There is also  a need to recogni/e that regional or local criteria are often more appropriate
17    benchmarks than national criteria (e.g  DO. TN. TP. TOO.   It is dangerous to oversimplify the
is    analysis by classifying  the data based on arbitrary breakpoints. The SAB notes that the
l1'    a\ailabihty of national  "indicators" (e.g..  \\aier clarity in  coasial /ones) should not be a reason to
2(i    include them in the ROE if they are not iruly  meaningful  indicators of ecological condition  In
21    this regard, the  United Slates  Geological Survey (USGS)  National Water Quality Assessment
22    (NAQWA) study provides a very good assessment of ambient water quality across a wide
23    number of watersheds.  However, \\hen this information was analy/ed by the Hein/ Center it
24    was presented only in lerms of presence of pesticides and other contaminants.  Presence is not a
25    useful indicator without the additional qualification of the toxicily associated with the
2<-    concentrations found. An important question to answer is whether there  is a human health or
2"    ecological risk associated with these toxic contaminants in water  Water quality  criteria are
2s    available for  mam contaminants and the criteria can be used to put concentrations in perspective.
2"    producing a more useful indicator  At the very least, a presentation of the available water quality
     criteria (eg..  Criterion Continuous Concentration. Criterion Maximum Concentration, and
     Maximum Contaminant Level) for the contaminants thai  exceed these values could be included
     in the description of the "presence" indicator  A similar approach could be taken with regard to
     contaminated sediments,  using guidelines such as Probable  Effects Concentrations (MacDonald
 •»    et al.. 2000) to put their loxtcily into perspective.
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     Omissions from Chapter Two (Purer  Water) of the draft ROE

 x       The SAB  finds that a number of important indicators have been omilted from the water
 i)    chapter of the draft ROE.  National datasels for these indicators are available and should be used
-in    in the next ROE.  Although it is useful to  know thai more than 94% of drinking water suppliers
-il    are in compliance with drinking water standards, it is also important to prov ide information
-12    regarding the violations of drinking  water quality standards.  The ROE should report the seventy
-13    and frequency with which different standards are v mlaled and the spatial distribution of
•44    violations across the  United States   Knowing the nature,  severity, and spatial pattern of drinking
45    water v iolalions (e.g.. pathogens, arsenic) would help identify potential sources of contaminants
-if.    and help to correlate diseases wilh contaminated water. The SAB recommends that this

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information be prov ided in order to address two missing drinking water quality indicators:
sources of contaminants and human health effects.  In a similar vein, identifying the most
common contaminants that lead lo fish and or shellfish advisories, as well as the seventy of
exceeding risk levels, would help identify sources and make linkages lo human health effects

   Section 2.2.1 of the draft ROE (Condition of fresh water and watersheds) contains no
discussion of Clean Water Act Section 3()3(d) listings. These listings reflect water body
impairment and could be discussed in the ROE. The 3(>3(d) listing information was developed
based on slate or federal water quality objecliv es for designated uses of ihese water bodies, and
the achievement of these objectives  Although ihere are questions regarding both ihe statistical
basis for listing a water body and the scientific basis for some local water quality objectives, the
303(d) lists provide a national v iew of the condition of watersheds. Since the 303(d) lists are
based upon local and state data that may  be inconsistent across political or administrative
boundaries, the lists have limitr.lions similar lo those associated with beach closings and fish
advisories.  However, the 303(cl) lists prov ide an important measure of the nation's progress
toward achieving water quality objectives.  The fact that water quality objectives reflect local
values should be considered a strength, rather than  a limitation because the objectives reflect
criteria that are adapted lo local conditions.

   National Pollution Discharge Elimination  System data capture nutrient, toxics, and thermal
loads lo waier bodies, and the daia are available al ihe national level.  The SAB recommends
thai Ihese dala be organi/ed and included in the ROE in order to show temporal trends.  This will
provide information to determine whether the loads of N. P and the most important toxic
compounds to waters in  the United States are decreasing or increasing.  NPDES data should also
be used  to determine  the spatial distribution of load reductions (e.g.. identifying regions which
are lagging in the reduction of loads, and relating loads to observed \vater quality and 303(d)
listing).

   The water chapter of the draft ROE currently contains a discussion of changes in stream How.
The SAB recommends that this discussion be expanded to provide information on stream How
and its relation to observ ed climate change    Stream How information should also be presented
spatially.  It would be useful to view changes in precipitation nationally and regionally  to
determine how thai has influenced stream How. A related issue that should be included in ihe
ROE is  ihe change in global temperature and how it is affecting the liming of snow meli.
parlicularly in the western United Slates, where it can have a major impacl on water resources

   The SAB recommends that, in addition to the suggestions outlined earlier in this document.
the following indicators  should also be included in the water chapters of future reports:

   •  Changes in groundwater quantity and quality at a regional lev el. which can then be
       integrated lo give a national perspective on the stale of our groundwaters. including
       ground subsidence due to excessive withdrawal, increases in nitrate concentrations, and
       fraction of drinking water supplies affected by MTBE. PCE. TC E. BTEX and other
       important contaminants;

   •  Changes in water temperature due to point source discharges (i.e.. power plants  and other
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       such uses of water) and riparian alterations of the landscape:

    •   Status of invasive species in aquatic ecosystems;

    •   Changes in TDS/saliniiy over lime due to human activities:

    •   Quality of irrigation \\aler {e.g. salinity, nutrients, toxics):

    •   Detection of emerging water pollutants in \\ater supplies across the nation;

    •   Harmful algal blooms.

Validity of conclusions in Chapter Two (Purer Water) of the draft ROE

   The SAB notes  that despite data gaps, main of the conclusions in the water chapter of the
draft ROE are supported by scientific information.  I lowe\ er some conclusions contained in the
draft ROE are problematic or need qualification.  In some cases, the draft ROE presents no
conclusions and data are presented without analysis. These problems are listed in detail in
Appendix A of this SAB report, but a feu  are identified below for illustrate e purposes:

1>  Page 2-15:  Data interpretation is confounded b\ the graphical presentation.  In exhibits 2-6
    and 2-1. the lime scales are confounded by using equal spacing despite co\ ering different
    periods of record. In addition, the use of different scales on the y-axis can lead to
    misinterpretation of trends.  Although the absolute  changes in exhibit 2-6 are relativ ely
    similar (ca. 5000 acres lost or gained for each \\elland type between the 5()s and 70s), the
    relative difference is much greater for shrubs (41 "
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    lo\\ard the high end. E\ en EPA's nutrient criteria guidelines suggest that a louer standard is
    appropriate. This issue desenes greater attention since impairment is likely at 100 ppb. It is
    also not clear how often samples were collected, \\hether slonr events uere sampled, and
    when total phosphorus is likely to be elevated.

The kinds of information discussed  in the cases listed above should be pro\ ided for other \\ater
quality indicators in the draft ROE as  \\ell.

Indicators in  Chapter Three (Metier Protected Land) of the draft ROE

   The motivating questions and related indicators included in Chapter Three (Better Protected
Land) of the draft ROE  are.  wilh lew exceptions, good  While recogni/ing that the sub-themes
of Chapter Three (land cover, chemicals, and \\aste) do not necessarily hold together coherently
when viewed  apart from the rest of the document, the SAB belie\es that their placement together
is appropriate in light of the recommendations made about the structure (and recommended
restructuring) of Chapter Fix e. One indicator that is not really helpful in Chapter Three (or
anyplace else in the ROE) is "extent of" forest ownership." This metric is not relexanl to an
understanding of em ironmental quality. The SAB also notes  that Chapter Three is missing
many important indicators.  Some of them are presented in Chapter Fi\e. and the SAB
recommends that they be moved into Chapter Three. Specific indicators that should be moved
from Chapter Fi\e into Chapter Three are identified below.

    A number of important land use indicators are not included in the draft  ROE. and the SAB
recommends that they be added to future drafts of the report.  These indicators include: the
extent of roads, metrics related to sprawl, and metrics related  to socio-economic distributions of
the human populations in relation to various land uses and land-based sites of contamination.
The SAB recogni/es that the EPA may not be able to find data to apply to all of these indicators.
but because the indicators are meaningful and important they  should be mentioned in the report.
When necessary. EPA should explain  that no data are currently available for the indicators.

Data gaps and limitations in Chapter Three (Hetter Protected Land) of the draft ROE

   The SAB is concerned abou; the  tone and content of the discussion of some "indicator gaps
and limitations" in Chapter Three of the draft ROE.  It  is not always clear whether data gaps and
limitations in  this chapter are identified because the indicators cannot provide answers to
questions, or because few data are available to assess the indicators  Most of the gaps and
limitations in  Chapter Three are slated in such definitive terms that they unnecessarily convey to
the reader that the data ma\  be inappropriate or unable to ans\\er ihe question.  In fact, many of
the data sets used for these indicators are accompanied by  error estimates or assessments of
confidence le\els: thus the extent to which indicators are limited by data ax ailabihty can be
assessed. When estimates of accuracy are available for data sets, they should be provided in the
ROE. The SAB also notes that some of the statements in the  draft ROE about gaps and
limitations are incorrect. Examples  of these are included in Appendix A. Some of the staled
gaps and limitations are. in fact neither. For example, ihe second gap/limitation list on page 3-
31 merely stales thai the available technology to detect residues exceeds  \\hal  is needed  to detect
le\ els of residue thai have health consequences. This statement does  not call into question either

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 I    the indicator or the data.  Therefore the statement should not be included in the report.

 .1       As mentioned previously, the SAB recommends that EPA rethink the indicator gap and
 4    limitations (IGL) approach presented in the draft ROE  In the current draft of the ROE. the IGL
 5    sections in all of the chapters contain an assortment of qualifiers that often inappropriately
 6    discourage the reader from believing the data presented. The SAB feels that this is largely a
 7    result of poor definition of the IGL section, and an apparent need to include information in the
 s    IGL section for each indicator, or the selection  of an inappropriate indicator or measure for that
 9    indicator.  IGL  segments in the draft ROE include: (I) actual data gaps (pages 3-22. 5-12): (2)
10    actual limitations (pages 5-39): (3) descriptions of the data (pages 3-20. 5-12): (4)  needless
11    apologies for data that are too accurate (page 3-31): (5) descriptions of problems that are not
12    problems  (page 5-16. Breeding Bird Suney and volunteers): and K>) vague descriptions of things
l?    that may or may not be problems (e.g.. page 5-15 states. "It is not clear that trends can  be
14    quantified \\ith any precision").  A fe\\ segments report data uncertainty (page 5-12. end of first
15    bullet).  This assortment of qualifiers lea\ es the reader feeling be\\ ildered and unnecessarily
16    confused.  If an indicator must be qualified the  use of that indicator should be reassessed to
17    insure that it is truly reliable and reportable.
is
is)       The  SAB recommends that indicator gaps and limitations should be provided in detail in an
20    appendix  (currently Appendix  B of the draft ROE 'icchmcul Document) that fully  describes the
21    rationale for indicator choice, data sets used, data sets not used, and constraints on these data
22    sets When these descriptions are placed within the body of the technical report, they are
23    distracting and often portray the data in an unrealislically poor light.  The SAB also recommends
.4    that EPA  should not label accuracy statements about data as a gap or limitation. For example.
25    the fact that the national Pesticide Data Program (PDP) can detect pesticide residues at
26    concentrations below regulated levels is an asset to the data, not a limitation. Data relevance is
21    also a critical issue in assessing data limitations that is not sufficiently interpreted in the draft
2s    ROE. For example, assessing soil erosion on undisturbed forested lands (page 5-22) seems to
29    have little meaning when it is known thai most  forest soil erosion is associated with harvest.

        The  SAB also notes that data omitted in Chapter Three of the draft ROE is also a critical
     issue. Se\eral notable data sels are used sparingly in the draft ROE (Breeding Bird Suney.
     NatureSene rarity ranking. Forest Imentory and Analysis |FIA| plot data). Other metrics are
     a\ailable  from these data sets (e.g.. population  trends of grassland birds) and the lack of explicit
     detail explaining why some portions of ihe data sels were included in the draft ROE. and others
     \\ere not.  raises concern among people familiar with the data sets.

     Organizational scale of ecosystems in C 'liapter Three (Ketter Protected Land) of the draft ROE

        The  SAB finds that the current draft of ROE Chapter Three addresses indicators of terrestrial
     ecosystem extent and condition with a taxonomy and at a scale that are not appropriate. The  use
     of just four land use types (developed, farmland, grass, shrubland. and forest land)  is not adequate
     to accurately inform the public about questions of national importance pertaining to the condition
     of land  or the ecological consequences of land condition. As an example, the category of
     grassland/shrubland/desert lumps together numerous well-recogni/ed ecosystem units, such as
     lallgrass prairie habitat,  short-grass steppe, cold desert, warm desert, and mam  others  The

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problems thai face different ecosystems are quite different  For example, habitat loss of tallgrass
prairie, as well as most other eastern U.S. grassland types, is nearl\ complete (estimates
generally report greater than 9')% loss).  A United Stated Department of Agriculture (USDA)
report on ecosystem endangennent lists multiple endangered ecosystems \\hich are eastern
grassland. Yet. the draft ROE summari/es the extent of the broad grassland category as quite
high (85-94"<> extant, though it does acknowledge that the quality has changed, p. 3-18). This
results in a misleading interpretation of this system. In addition, threats to systems cannot be
well captured at the resolution currently described in Chapter Three of the draft ROE.  A leading
concern for grassland integrity of eastern lallgrass prairie is the on-going conversion of
pastureland to ro\\ crops, leading to the decline of numerous grassland-dependent bird species
(HerkerL 1994. 1995).

   In future editions of the ROE. the EPA \\ ill face a number of hard decisions regarding
classification schemes for ecosystems  Different data sets, summari/ing different indicators of
land condition, use differing ecosystem classification schemes. Often these different ecosystems
are not easily compared.  Some are based on physiognomy, others on bioclimatic /ones, and still
others on dominant species. This will result in difficult decisions \\ith respect to data treatment.
Future reports on  the environment may be organized around the currently used types (forests.
grasslands, etc.). but the SAB recommends that indicators must, \\here\er possible, use
meaningful ecosystem classifications. These should be.  as a rule, at a finer scale than the broad
types currently described  in the draft ROE.

   The SAB offers the  follo\\ing five recommendations  regarding selection of an ecosystem
classification scheme for  the ROE.  1 ) Choose an ecosystem classification scheme that
summari/es ecosystems of the United Stales in approximately 20 different fundamental
ecosystem units for reporting on the environment. The approximately 20 ecosystem types would
include the wetlands, estuaries and marine ecosystems described m Chapter Two. The Vector
Smart Map ( VM AP) project uses one such scheme  2) When using data from other studies  thai
use a hierarchical  classification (e.g.. NalureSene). trim the ecosystem classification scheme to
this same le\ el (approximately 20 units). 3) When using data thai do not trim well to this order of
magnitude (United Stales Fish and Wildlife Service |USFWS| Forest Inventory and Analysis
| F1A|) data, it is possible to use summaries at a coarser scale (e.g.. ihe order of the forest
classification used in the Hein/ report), but EPA should  note that most rare and threatened
community types  reside in the category of "other forest types." Thus, statements interpreting
trends in forest cover must be constrained by  the fact that there is no information presented  on
the loss of forest types, because the ones most likely to be lost are aggregated into an "other"
category. (4) We  encourage EPA to use particularly sensiti\ e ecosystems as a focal area upon
which to report indicators. For example. ri\ers and oceans are ireaied as large ecosystem
categories in the current report, but prominent bays and estuaries are critically important
ecosystems for both biodiversity as \\ell as extractive resources. These ecosystems share two
additional attributes: they are v er\ susceptible to degradation and perturbation because of human
impacts,  and there is a large and robust set of data describing the conditions of these ecosystems.
Judicious use of critical ecosysiems can be very useful for characteri/ing condition at a broader
level.
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 1    Questions in Chapter Three (Iletter Protected Land) of the draft ROE

        A deficiency of the draft ROE is that questions are framed differently in the land chapter in
 4    comparison to the air and water chapters.  In some cases questions are framed to answer
 5    questions about extent of ecosystems, and in other cases they are framed to answer questions
 6    about ecosystem condition  Answering questions about condition requires a different suite of
 7    indicators than those currently used in the report. The SAB recommends revising the questions
 s    and  indicators to make them more illuminating of actual ecosystem condition.  In some cases the
 9    use of new indicators may be appropriate  In developing the next ROE the EPA should consider
10    framing questions to reflect land condition. The SAB provides examples in Table I.() of (he
! 1    kinds of questions and indicators that might reflect forest condition.  Similar kinds of questions
12    and  indicators can be developed for v anous types of grasslands, deserts, and aquatic systems.
n    These examples are neither intended as an exhaustive list, nor a specific prescription for choice
14    of indicator. The SAB recommends lhal the authors of the next ROE think hard about which of
15    these indicators may be obtained and analy/ed in the short time av ailable for preparation of ihe
Ui    report. The SAB also recommends that F.PA begin thinking about the activ ities lhal may be
r    initiated now in order to expand these indicators in the future, given the current constraints on
is    monitoring.
i1)
2o        It is likely that stale-collected data on wildlife health status  can be used as indicators of forest
21    condition.  Wildlife status indicators lhal could be developed include: tick loads of deer:
22    morbidity (papiloma on deer), and peregrine eggshell thickness. EPA should also consider using
2?    breeding bird data on neotropical migrants Multiple data sets for the same indicator should be
24    compared in table form.  Very few differences are likely lo be observ ed in agricultural land, but it
25    would be useful to know about transformations within agricultural land.

27       The SAB notes that Chapter Three of the draft ROE also pro\ ides information on indicators
2s    of waste and toxic contaminants released lo land The SAB did not comment on this section of
2-)    the draft report because the SAB  ROE Panel did not have the expertise to assess the information
     provided  However, the SAB notes lhal the ROE should contain a discussion of the problem of
     intense land contamination by discarded chemicals, leading to such problems as leaching into
     ground water and potentially toxic human and w ildlife exposures.  Such contaminated  sites are
     sufficiently  widespread lo constitute a national problem even though each site may be relatively
 4    isolated.
 5
 (<     Indicators in Chapter Four (Human Health)

          This Chapter lacks an overall framework that would relate the health indicators lo the
     environmental stressors presented in the other chapters The SAB recommends that some
4ti    additional indicators be added lo Chapter Four of the draft ROE.  Endocrine disruptors in the
II    em iron men t should be addressed and consideration should be given lo adding indicators of: time
42    of puberty, teslicular cancer, prostate cancer,  sperm counts and function, gender ratio at birth.
4.'    and  thyroid  disease  In addition,  neurobehav ioral function (including cognitive function, v isual
44    memory, etc.) could be listed as an environmental health indicator.  The discussion of relative
45    rales of infant mortality in Chapter Four should indicate lhal the high proportion of teenage
41 >    mothers is one reason why infant mortality in the l.'nited Slates is high.  Chapter Four currently
47

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Table I.():  Poss ble indicalors of condition and response to stressors
                      (Question: WViat is i he extent of tores! habitat diversity ;md contiguity'.'
   Rationale lor selecting question: We know that plant coiniminily diversity determines food chain structure.
   Disruption of community divcrsiu degrades ecological integrity.

   Indicators:
   l;oresl Community Diversity . Despite the observation (hat overall forest quantily has. il'anything, slightly
   increased during the p;isi In \ eai>. there arc likclv numerous way s b\ whic i changing land use continues to
   threaten biological di\ crsiiv  of forests. ()ne indicator of habitat loss as a slressor would be changes in the
   quantity ol" lores! ly pes that are rare anil threatened.  Indicator opportunities: iii) spatial and temporal changes
  I in rarity ranks ol"threatened  forest ly pes chased on NatureServe classification scheme v. I bi Changes in spatial
   extent of key community types.

   Habitat Patch Si/e Ideological data indicate that the si/e of forest fragments has an important effect on
   species richness te.g . birds,  mammals, amphibians i and on trophic structure < i e.. the presence or absence of
   top predators). A critical indicator of forest patch sr/e can be captured throng i an index of changing road
   density as well as geostatistical appioaehes to remote sensing data (i.e.. FRAtiSTATS on land cover data).
   Indicator opportunities: (ail X > I  Road density data, (b» Random selection of representative forest patches
   distributed across the U.S. using ! ANDSAT data: ic) Millenium ecosy stem assessment t This report should
   be completed soon, and it provide-; global data analysis, .so that patch attributes in the I Inited States could be
   compared to other parts of the world)
                         Question. Are invasive species degrading forest prod.ictivily'.'
             ___
 :  Rationale for selecting question: I n asive species are competitive dominants 'hat displace native species.
   disrupt hiogeochenueal cycles: and engineer abiotic environments  Invasive species represent ilie second
   leading cause (behind habitat lossi of species cndangennenl on the 1 "nited States. < VVilcove et al. I WXj.
   Indicators
  I Acreage spread of kev invasive species. !ndicator opportunities; I 'SI'S and HI,M track acreage spread of kes
  i invasive species. Numerous stale and local agencies map regionally imporUiir. in\'asi\'c species (e.g.. ha\ -
  j scented fern in New Kngkmd. garlic mustard in the upper Midwest, kud/u in  I he southeast, scotch broom in
  1 the \\est i.  Regional  trends and casj studies can be used to illustrate a problem of national scope and concern
                        Question: What is the ecological condition of forests', i forest age'	
  ! Rationale for selecting question. 1'oiest age is an indicator of siandmg productivity and a surrogate lor the
  I likelihood of disturbance (e.g.. fire susceptibility i; disease or pest invasion: and a measure of degree to \\hich
  i 1 J.S. forests are represented by old growth stands.

   Indicators
   Indicator opportunities: Forest Ago data from i ISFS MA plot data: classified into \ !SFS community types:
   perhaps by biome  A sequence ol spatially explicit maps can he used to sho',\ time trends using isoclines ol
   net grouth across the countr\
  	(Question. What are trends in Ihe disease slate of forests1' (Insect pests ind microbial pathogens;
   Rationale for selecting question: An indicator of forest tree health is pests and pathogen outbreaks.
   Indicalors
   Indicator opportunities. IMnbii 5-ld ol the draft ROM provides a temporal trend in acres of forest impacted
   by insect outbreaks and disease. This trend is problematic in ihai it is dilTici.lt to discern a single outbreak.
   event in the IMSO's. from \\hieh w.' are experiencing a recovery, or a real  trend toward fe\\er outbreaks. A
   spatial analysis combined \\ilh this temporal analysis \\otild allo\\ these dat.i to reveal whether there \\ere
   chronicalK higher insect outbreak levels in the h'Su's or if this peak results t'lom a single large event and
   subsequent recovery. Additional opportunities include the spat;al spread of prominent insect pesls such as
   gypsy moth, woolly udelgid. Japarese ash-borer for insects: dogwood anlhrac lose, while pine blister rust and
   others among tree diseases  I 'SI-'S collects data on these infestations.	 	

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 2   does not provide any reason for the relatively high infant mortality rate in the United States, and
     readers max1 conclude (inappropriately) that it is completely a result of exposure to
 -I   environmental chemicals and not related to socioeconomic conditions. The discussion of lead in
 5   Chapter Four (case study) should reference articles in the April 17. 2003 issue of the M-tv
 f>   l-'.n^lunJ Journu!ofMcili^nK' providing evidence  that even the current "acceptable" blood lead
 7   level of 10 micrograms/dl may not be protective of health.  These articles reported that: 1) serum
 x   lead levels of three versus one micrograms/dl delayed puberty by several months in blacks and
 •)   Hispamcs (but not whites), and 2) IQ was adv ersely affected by serum lead lev els even up to
lu   only ten micrograms/dl. with most of the loss between the levels of one and five micrograms/dl.
11
12      The SAB recommends sev era! other additions  to Chapter Four  Brain barrier differences in
i ?   children are discussed as a reason for the susceptibility of children to environmental
i-i   contaminants.  It should he also be noted thai end  organ susceptibility max be equally or more
15   important.  Breast milk monitoring should be considered as a method  for determining the body
K>   burdens of many of the most worrisome chemicals.  The SAB also notes that old  data on the
\1   incidence and rising incidence of autism are used  in Chapter Four. Current estimates for autism
is   spectrum disorder are 6.7 per thousand. New technologies should also be discussed in greater
i"   detail in Chapter Four. These include the use of genotypes and more sensitive and specific
2n   neurobehav icnal testing (e.g.. visual memory testing and functional VIRIs). Chapter Four is
21    focused on disease causation  It should be noted,  however, that em ironmental chemicals max1
22   not cause certain diseases, but max exacerbate disease processes such as asthma and cystic
21   fibrosis. Neurobehav ioral function in typical and dysfunctional children may also be affected by
24   environmental chemicals.  EPA should also link longstanding stale databases on health such as
25   cancer registries and birth defects to environmental data sets. Data from the CDC s
2f>   Environmental Public Health Tracking Project max  be available to provide this type of
2"   information for the next ROE.  In Chapter Four EPA should also consider addressing emerging
2s   persistent chemical  contaminants such as brominated flame retardants and perilurooctane
21'   sulfonate.

        The SAB also notes thai there is extensive peer-rev iewed literature documenting associations
     between PV1 and o/.one pollution and human health  effects such as respiratory morbidity and
     cardio-respiralory mortality.  The arbitrary  insistence on "national scale" data seems to have
     obscured these important findings in l-PA's draft  ROE 2003.

     Indicators in Chapter Five (Ecological Condition)

 s      The SAB finds that the status and trends of ecological conditions at the regional and national
 l>   scale were not communicated well in Chapter Five of the draft ROE. and it was difficult to
4d   understand xvhy EPA had judged main of the indicators as important to include.  For many
41    indicators, both the  value of the indicators and supporting information is diminished by the way
42   the indicators were presented, developed, and assembled in the report. Some examples  of these
43   deficiencies and recommendations for improv enient max help EPA make the Report on the
44   Em iron men t more clear, concise, and persuasive.
45
46      Several indicators collapsed data and measurements into pooled or average values that are too
                                                24

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generali/ed to com ey clear information on environmental status and trends. For example, the
pooled surface area of lakes and reservoirs (exhibit 5-25) sho\\ little change in a five-decade data
series spanning the era of dam building in the Lulled States from llie l%0s through the 1980s.
Also, the desirability of increases or decreases in lake and reservoir area is not evident or
explained  The statement that 'changes in this indicator reflect the effects of climate on water
lex el..." is greatly oversimplified and misleading.  Report sections on indicators often provide
numerous qualifications on indicator use. and at times go so far as lo slate that indicator \alue
changes cannot distinguish natural from human pressures (e.g.. marine mortalities). The
problems and reservations on indicator clarity, precision, and interpretation can be greatly
reduced by limiting indicators 10 those that have a direct relationship to specific environmental
changes, and indicators known to be sensitive to targeted trends.  The ideal indicator \\ould be:
(1) based on familiar and easily understood measures: (2) based on data known to be strongly
correlated with the em ironmental attribute of interest. (3) and relal vely insensitive to
confounding and non-em ironmemal factors.

   The SAB finds that in Chapter Five of the draft ROE there is frequent redundancy among
indicators and with regard to their intended interpretation.  Chapter Fi\ e appears lo collect
indicators from the basic chapters on air. land, and water. The repealed use of related indicators
can be helpful for reinforcing a status or trend conclusion, but the SAB percei\ es this practice as
an impediment to developing a clear and concise message on the ecological condition of the
environment.   For example, there are three indicators based on animal, fish, and marine organism
deaths and deformities even though strong reservations are stated for interpreting each one. In
another example,  model results are used from a single go\ eminent database to project indicator
values for two closely interrelated indicators: soil compaction and soil  erosion.  Rather than
amassing related indicators win suitable data, the SAB feels that (he overall impact of the ROE
will be greater if the most informalive and well-supported indicators are used to answer specific
questions and show specific trends

   The SAB feels strongly that there are loo main indicators included  in Chapter Five of ihe
draft ROE. and loo many  for a number of the ecosystems assessed  While we support ihe
numerous indicators in the chapters on air. land and water, we believe that the overarching
chapter on ecological conditions should concentrate on a limited number of select indicators.
Large numbers of indicators can impede communication when an ov erall sense of status and
trend is being sought.  This chapter of the draft ROE includes  74 indicators, with the number per
ecos> stem type ranging from 4 to 1 (•>. Most people can recall and s> nthesi/.e as many as 7 lo 9
facts or values. When findings come in greater numbers, readers will conduct their own
averaging or counts lo gather an o\ erall sense of status.  The SAB therefore notes thai seven or
fewer indicators per assessment realm (an ecosystem type, region, or ihe nation) is an optimal
number, and additional indicators only complicate gaining an  understanding of environmental
slalus and trends.  The SAB recogni/es that cutting the  number of indicators lo a few or several
per assessmeni level poses a ver> difficult challenge. Selecting a few well-supported, sensitive.
and precise indicators is a substantial technical challenge. It also runs counter to the natural
interests of agency programs, report participants, and interest groups who often want lo see their
work and resources highlighted.  Nevertheless, the SAB feels  that relying on ihe slrongesl and
most in formative  indicators will considerably strengthen the impact of ihe total message and
increase ihe influence of Ihe report.  If EPA decides that the best approach to assessing the

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 I    ecological condition of each ecosystem is lo synthesi/e multiple indicators, then perhaps the
 2    multiple indicators could be included in appendices, with the synthesis for each ecosystem
 3    presented in the report, along with the synthesis for all the ecosystems in each region, or the
 4    Nation.
 5
 (>       The section of Chapter Five that discusses essential ecological attributes captures only a
     limited set of human dri\ers of ecological change. The drivers considered in the draft ROE are
 s    mainly those associated with physical alterations of the habitat and the impacts of that alteration
 l.»    on ecological health.  There are other human drivers that have marked impacts on species
in    populations and ecological health. For example fisheries can have direct impacts on the
11    biological condition, growth characteristics, life histories, and genetic composition of the
12    targeted  species  However the impacts of fishing can extend beyond the target species to other
13    aspects of the ecological community.  For instance, changing predator abundance and si/e
14    distribution  can alter forage species characteristics and composition, and consequently impact the
15    species that  serve as the food source  for foragers.

i"       There are other less obvious ecological impacts thai can result from human drivers.  While it
is    is widely recogni/ed that waier quality influences biological communities, the integrity of
il>    ecological community structure can influence the sensitiv ity of the community to water quality.
20    The depletion of filter feeders and gra/ers can adversely affect water quality through reductions
21    in filtration of plankton and suspended sediment or through a reduction in graying of plankton or
22    other algae.  The resulting increases in turbidity or decreases in plankton can have substantial
23    impacts on water quality and remaining biological communities.  For example, the loss  of oysters
24    (Illter feeders) and the depletion of menhaden slocks (plankton gra/ers) in Chesapeake Bay have
25    led to increased turbidity and planklonic primary productivity. In mam coral reefs, a persistent
2f>    shift from coral lo macroalgnl dominance has been attributed to a reduction in herbivorous fish
27    and invertebrates, causing increasing ambient lev els of nutrients  lo be channeled into less
2s    preferred aulolrophic forms, resulting in less material being transferred directly  to higher trophic
2i>    levels. Alternatively, increases in bollom-feeding fish in ponds and small lakes can lead to
30    increases in the suspension of sediments,  increases in planktonic production, and a decrease in
     bottom vegetation due lo reductions in light penetration  We therefore recommend that
     indicators offish slocks and diversity for coastal, estuarine and Great Lakes fisheries be
     developed and  discussions  of how the condition of fisheries  can impact water quality be added to
 4    the discussion of ecological conditions
 5
 c>    5.3.   Ones/ion 3: (Conventional Agency practice has heen lo measure and reduce emissions
 7    and subsequent exposure to pollutants. ('an von surest how measurements for human health
 x    anj ecological com/ilion impacts resulting from environmental perturhaiion coukl he more
 l>    effectively aJJi
41    A.  Key Recommendations in Response to Charge Question 3
42
43     The SAB prov ides the following key recommendations lo enhance synthesis in the human health
44    chapter of the draft ROE
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             Presentation of the stale of the environment in a health context greatly enhances the value
             and meaning of the ROE while at the same lime complicating it. The linkages described
             in the draft ROE are extremely imporlanl in representing (he state of the environment as
             il relates to human health. Ho\\e\ er. the SAB notes that health impacts resulting from
             em iron menial pollution should be addressed in the ROE through a more rigorous and
             systematic consideration of their linkages
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2.  The criteria for identification of em iron mentally related health effects should be
    identified and included \\ilhin future human health chapters. Because of the technical
    challenges associated w ilh identifying health effects associated with lo\\ level chronic
    exposure lo environmental contaminants (e.g.. endocrine disrupters), there is scientific
    bias in favor of identifv ing health effects associated v\iih acute exposures. This bias is
    reflected in the draft ROE. although il is addressed in section 4.3.5 of the report through
    identification of emerging health effects

3.  The selection criteria for identification of health effects should take into account the
    precautionary principle (i.e.. the magnitude of the public health threal should be
    considered when determining the requirements for weight of e\ idence and/or strength of
    association)

4.  For those diseases that are included in future human health chapters, a clear description
    of the role  and strength of evidence that relate a disease tc pollutants in air. vvaler. land.
    or diet should be pro\ ided. Bradford-Hill criteria should be considered in character!/ing
    the nature of the eviderce and strength of association.

5.  For many  environmental pollution-related health effects, exposure and effects
    susceptibility are key considerations and should be discussed in the context of linkages.
    Where appropriate, susceptibility factors such as age. gender, polymorphisms, and
    socioeconomic status should be acknowledged  The differential impact of the
    environment by  socioeconomic status is particularly important as an issue of
    environmental justice. This differential impact may be a result of environmental hot
    spots or susceptibility (e.g.. inadequate health, poor diet).

6.  The current document does not adequately treat the health threats posed by environmental
    contaminants in diet  Diet represents an imporlanl route of exposure for a wide range of
    contaminants (e.g.. peslicides. metals. PAHs.  heterocyclic amines) representing an
    mtegraliv e medium across air. water, and land.  The U.S. Department of Agriculture and
    or Food and Drug Administration have databases that are likely to satisfy the criteria for
    category 1  or category 2  indicators.

7.  The seclion on emergirg health effects (Seclion 4.3.5 on page 4-38 of ihe draft ROE).
    particularly that part ol the seclion on arthropod-borne diseases (page 4-40). should be
    linked to the ecological condition seclion of the draft ROE (Chapter Five, or those parts
    that are moved into Chapter Three). This seclion is important because of the growing
    awareness  lhat many "new" infectious diseases emerge in large part from changes in the
    em iron men t.  These diseases, in turn, can result  in changes to the environment as well.

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       in their linkages to ecological attributes of human concern (e.g. the Chesapeake Bay and
       the Great Lakes where contaminated sediments, fish ad\ isones associated with high
       le\els of mercury and PCBs. and beach closings caused by oalhogens in recreational
       waters link environmental perturbation lo human health risks).

B. Specific Comments in Response to Charge Question 3

Linking environmental exposure anil human health effects

   "Hie linkage between environmental exposure and human health is addressed in Chapter Four
of the draft ROE. The SAB believes that the following approaches and suggestions will help to
make this critical linkage. The SAB recommends that the overall document should be
reorganixed and a conceptual s jmmary should be included at the beginning to help set the stage
for a discussion of links between exposure and human health effects.  The SAB also believes that
il will be important to look for and include additional measurements that are intermediate
between ambient concentration and human/ecological effect These can include measures of
personal exposure, biological markers of exposure, measures of body burden (the direct result of
exposure and uptake), and measures of sub-clinical change.  Ambient concentration does not
directly describe exposure and uptake of toxic materials from the environment. Within the
context of the conceptual  model outlined at the beginning of the document, measures of personal
exposure to compounds with known health/ecological implications are one step closer lo an
index of health impact than ambient concentration. In addition to the examples currently
included  in the draft ROE. which are restricted  primarily  to blood levels of hea\y metals.
additional possibilities lo explore include: Pb and other bone seeking elements and radio-
nuclides in bone (a more stable measure of integrated exposure than concentration in  blood.
which has a relatnely short half-life): heavy melals in nail and/or hair: bio-accumulating organic
and inorganic pollutants in human breast milk: carbox\ hemoglobin (COHb) levels as a marker of
exposure to emissions  from combustion sources: exhaled brealh concentration  of \olalile
organics: and hea\y  melals or metabolic byproducts of organics in urine. The SAB recogm/es
that data to support the de\ elopment of indicators for many of these markers of exposure may
not be available from national representative surveys. However,  movement in  this direction is
important to establish linkages between the condition of the ambient environment and
human/ecological impact.

   Evaluating sub-clinical changes resulting from environmental exposures is another strategy
for linking exposure and effects.  For example, there are well-dev eloped relationships between
exposure to o/.one and pulmonary function. These effects have been demonstrated in a wide
range of individuals including asthmatics and healthy exercising adults. Recent studies have also
demonstrated ihe use of protein adducls and DNA adducts as measures of exposure. Within this
general context, it is important to consider mixtures and multiple routes of exposures.  In the
toxics area, effects are likely lo be at least additiv e or possibly multiplicative, and exposure can
be from air. water and  food. It also may be necessary to consider health and ecological outcomes
when the causal relation between exposure and outcome is not completely confirmed.  This
relationship is especially important in light of the potentially severe adverse consequences of not
acting to  mitigate ecological change.

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        The SAB believes thai il also will be necessary lo develop indicaiors of the impact of air
     quality change on ecosystem health. This linkage has the potential to lead to the direct synthesis
     of ecological and human health impacts.  Emission of climate forcing gases and aerosols is an
     obvious and important area for development. The goal is to track major ecosystem changes ihat
     result from env ironmental perturbation from the emission of pollutants. For example, ecological
     impacts with known health implications include habitat fragmentation and loss of biodiversity

        The SAB also recommends that emissions should be analy/.ed in a GIS context, incorporating
     climate, population, and other factors lo describe how people come in contact with pollutants and
     v ice v ersa  This analysis should include pollutants that may be derived from sources or processes
     not regulated by current EPA programs, acknowledging the fact that some impacts are derived
12   from sources outside the United Stales  For example, a systematic summary of global transport
13   (from satellite observations) could track the movement of Asian/African dust, which has
14   implications for coral reefs as well as human asthma  An additional example is an analysis of the
15   link between global deforestation and desertification with resulting dust events that can lead to
U>   ecological and health impacts.
17
l s   Synthesis to provide an integrated picture of ecosystem condition
19
2o      The draft ROE prov ides  many indicators describing the condition of air. water, and land.
21   There is. however, a need recogni/ed by both EPA and the SAB to combine information from
22   the air. water, and land  chapters and synthesi/.e them in ways that prov ide an integrated and
23   meaningful picture of (he condition or integrity of individual ecosystem types. In addition.
24   insights about condition of individual ecosystem types should be synthesi/ed to assess condition
25   of entire ecoregions or the whole country as data present themselves for future reports on the
26   environment. The SAB notes Ihat the current draft of the ROE attempts to do that, but the SAB
27   finds that the draft ROE lakes a decidedly single variable approach (e.g.. extent of a land use
2S   type across lime). The  limitation of such an approach is that it does not adequately reveal the
2i»   linkages and feedbacks among various  biotic and abiotic components that make up an ecosystem.
     nor does it  adequately assess indirect effects or unintended consequences. While the SAB does
     not suggest that future ROEs should contain a model of ecosystems that reflect real world
     complexity, ihe SAB does recommend thai these ROEs should contain some conceptuali/ation
     of important linkages among ecosystem components (e.g.. extent of land cover type and
     biodiversity) and then explore how certain drivers of environmental change lead to altered
     env iron menial condition (e.g.. extent of invasion by alien species which impacts the number of
     species and index of biodiversity  within an ecosystem: changes in air and water quality that can
     impact species and or habitat quality).  Doing this  effectively requires changing ihe
     orgam/alional  structure of Chapter Five of ihe draft ROE in two ways. First. EPA should
     develop a working concepluali/alion of how different parts of the ROE can be integrated
40   Second, the synthetic analysis of condition should be driven by major questions about
41   environmental problems
42
43   Example of information integration
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45      The synthesis of information should begin with a clear articulation of the specific goal of
4f.   analysis. What question is being asked for each synthesis?  It is presumed thai ihe goal of

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analysis for the ROE is to describe the condition or health of different ecosystem types.  This
goal begs the question, "health or condition in relation to what?" The answer to this question
requires defining the em ironmental problems of critical concern, for example, consequences of
global \\arming. consequences of biological depletion (biodi\ersit>  loss, habitat loss).
consequences of altered nitrogen cycling, etc.

   Descriptions  of ecosystem condition should then be expressed in terms of essential ecosystem
attributes  (EEA's). \\hich are influenced by a host of variables that determine the air. water and
land components of an ecosystem. The schematic in  Figure 1.() belo\\  describes a sample
approach one might lake to combine information from Chapters One. Two. and Three of the
draft ROE in  order to pro\ ide an integrated picture of the health of different ecosystem types and
of the United Stales.  The schematic pro\ ides an illustrative frameuork for understanding the
                         Hiiurt I.K: Illuslriitiii1 Kxnniplv fur Inlrgmtlng lnilic»tur« from Kco\y«lnn Ty|x>s into ii
                         AsM'vsNiciH <>!'.National IvcoLottit'iil Condition

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                                       lakes, rcscnoin. :(i;isul weilai
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     linkages among ecosystem attributes, function, and condition and builds systematically on many
     of the elements already included in the draft ROE. Such a schematic, by explicitly recogni/ing
     the end goals (or questions), can also be used to identify gaps and deficiencies in current
     monitoring data, thereby providing a planning tool for gathering future monitoring data.

     5.4    Question 4:  The k()I: focuses on indicators at the national scale.  Regional indicators
     tire highlighted in a few case studies. How useful are national indicators in presenting
     information on the quality of the environment'.' How much consistency is necessary in indicator
     measurements and data ifi/a/itv across the country'.' Should more detailed regional data and
     indicators he accommodated in a national overview of the environment, and how could this
     regional data he accommodated''

     A.  Key Recommendations in Response to Charge Question 4

        It is the opinion of the SAB that national indicators are useful when available because they
     can provide a broad overview of environmental conditions. Houever. the SAB strongly
     encourages EPA to expand  the use of local  or regional indicators and data in the ROE when
     these data can provide information about national condition1.  Il would also  be helpful to include
     more detail in the ROE on local trends and  examples, as a great deal of information is lost in
2ti   spatial averaging of air and  water pollutant concentrations. The SAB provides the following key
21   recommendations regarding the use of national and regional  indicators in the ROE.
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23       1.  The SAB recommends that indicators in the ROE should not be limited to those for
24          which data are a\ailable at the national lev el.  The report appears to  be more of a national
25          inventory than a description of national environmental health examination. Much can be
2(>          inferred from data a\ ailable at local and regional scales. A nationally focused
2"1          epidemiological approach masks important regional and local changes and impacts  By
2x          taking an exclusively national focus, potential issues  may not be noticed until they
2i>          become severe.

         2.  Additional categories of indicators and data should be further developed in the next
            iterations of the ROE.  Indicators that are relevant on a local  or regional scale, such as
            grounduater withdrawal in key aquifers and contaminated  sediment  levels in the Great
            Lakes, should be used to evaluate goals and assess progress toward the improvement of
            environmental conditions and public health at the relevant scale.

         3.  Approaches  that could be used to evaluate local and regional data include: determining
            whether criteria are  exceeded, evaluating data to determine whether regional goals ha\e
            been met. and integrating regional goals to evaluate national  progress.

41       4.  EPA must be judicious in choosing  regions from which data  are to be analy/ed and
42          presented. The use  of EPA Regions as frames of reference is probably arbitrary. The
4?          SAB notes that EPA has regional data available (e.g.. Regional Vulnerability
       The nutioiKiI condition is rvalh n composite of local and tvtiioiuil conditions, loo much averaging lends to lose
     inlonnation.

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       Assessment. ReVA). and these data should be reflected in ihe indicator exhibits of the
       ROE when they help to answer appropriate questions.

    5.  Spatial distribution information in the form of maps describing indicator data should be
       included in the ROE: when possible because these are \ er\ in formati\ e Greater use of
       maps in the ROE \\ould provide important information on spatial distributions that is
       largely lacking in the current draft  Exhibit 1-8 of the drafl ROE. which provides spatial
       distributions of PM:.?.  is a good example of how  maps  can be used to identify regional
       differences.

    6.  It is very important to use appropriate spatial or temporal averaging methods when
       describing indicator data. The SAB recommends that data distributions should not be
       averaged across indnidual EPA  Regions.  EPA should instead consider using areas like
       o/.one urban core sites for grouping and scaling data. It is also important to use an
       appropriate time basis  for reporting data.  For example, annual averaging of SO:
       emissions is appropriate, but annual averaging  of o/one data is not the best approach
       because of large seasonal variability and because averages are a poor measure of
       exceedence episodes

B.  Specific Comments in Response to Charge Question 4

I !se of regional data

   Regional (and even local) data are useful if the regions are  defined appropriately.  However.
grouping data according to EPA administrative region is arbitrary and should be avoided (e.g. the
o/.one distribution in Exhibit 1-11)  The appropriate grouping or scale will differ depending
upon (he particular indicator  O/one pro\ ides a good illustration Rather than grouping o/one
data by EPA Region, it would be useful to group the data by transport sites and urban core sites.
Another possible approach is to present  national data, and then present trends for particular hot
spots (e.g.. Los Angeles and Houston) and pristine areas in related vignettes to assess impacts.

   Charge question 4 asks \\he.her consistency in daia quality is required. While the SAB
recogni/es EPA's desire to use Category I or 2 indicators when  possible, the use of other
indicators is strongly encouraged if data are available and ha\e been reported in peer-reviewed
form.  This is particularly important in cases for which high quality  indicator data are available at
a local or appropriate regional le\ el. The SAB encourages the EPA to use such data in the ROE.
particularly where regional data could be used to draw conclusions about the national condition.
The SAB is concerned that EPA has included the statement, "no caiegory  1 or 2 indicators exist"
in tables such as Exhibit 1 -2 in the draft ROE Technical  Document.  This statement implies that
associations between, for example, human health and stratospheric o/.one depletion are not
known or do not exist.  It would be better for the table entry to include a statement such as "only
regional (local) data a\ailable: see section ***." This  could provide a reference to another part
of the draft ROF.

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Data averaging

   The SAB is concerned that llie extensive use of annual averaging in the draft ROE causes a
great deal of informal ion to be lost. For some indicators, such as SO^, annual averaging of
emissions levels  is certainly appropriate.  For others, such as o/one. annual averaging (exhibit I'-
ll ) is not the best approach, since annual averages are a poor measure of exceedence episodes.
It is also unclear in some cases whether reported annual averages in the draft ROE are for the
entire year or for the summer o/one season only.  Annual averaged o/one levels will be lower
than the averages restricted to the summer months.  The mean may also not be the most
appropriate statistic to use if data are nol  distributed normally.  If (he data are normally
distributed, one could consider inclusion  of standard deviation. If the data are nol normally
distributed, one might report median and range \\ilh some measure of uncertainty.

Data gaps

   The identification of data gaps and limitations is  an important part of the ROE.  In the draft
ROE. EPA effectively identifies explicit gaps associated with the individual indicators (e.g..
"o/one monitoring is conducted mostly in urban areas...").   Hov\e\er. as noted previously in
this report,  discussion of some gaps appears to be unnecessarily negatne (e.g.. "the indicator
does not present  actual  emissions data: thus, it has the inherent limitations of estimates...")  This
data gap could be staled simply by describing the approach used to estimate the data and
referring to Appendix B.  The SAB also notes that the discussion of gaps focuses on the specific
indicators that are listed.  It would be helpful  if missing indicators also were identified. For
example, in the indoor air section, the listed gaps are gaps in the reported data. Some indication
of useful indicators for  which  data are nol available  (e.g. indoor concentrations of formaldehyde.
    5) \\ould be  helpful
5.5    (.hiestion 5: The I'uhlic Report is in/ein/eJ to stimmanze the Technicit/ 1 >oc -timent 1<>r a
hroiul. non-technical puh/ic audience.  I iocs the 1'tih/ic Report accurately ana" adequately reflect
the technical content, including the gaps ami limitations. of the Technical Document'.'

A.  Key Recommendations in Response to Charge Question 5

   It is the opinion of the SAB thai the draft ROE J'uhlic Report should be restructured.  While it
reflects the technical  content of the draft ROE  'technical Document, it does nol convey
information in a fashion that is easily digestible by the public and possibly policy makers as well.
In particular, the public document reads as a distillation of the 'technical Document This makes
the Pnh/ic Report less useful than it could be.  Rather than only containing selected examples
from the Technical Document, the I'nhlic Report should also pro\ ide restructured and
recomposed information in a readily understandable format (i.e.. with language that is accessible
for those \\ilh a  10th grade education and beyond).  The Puh/ic Report could be a \aluable tool
to educate the public on issues identified in the report and on the relationship between human
activity and the environment. The SAB provides the following recommendations for
improvement of the draft  ROE Public Report:

    1 . The executive summary needs revision: there is no information in the executive

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             summary on human health and ecological conditions in the United Stales - this needs to
             be redressed

         2.  The 1'ithlic Report should be shorter in length: where appropriate, the report should
             contain hyperlinks lo llie Technical Document or relevant l.'RLs that prov ide supporting
             information. The supporting le\t does not ha\ e lo be in the Technical Document itself.

         3.  If possible, the graphics in the I'nh/ic Report should not be drawn only from the
             Technical Document.  Graphics in the f'tihlic Report should be simple and user-friendly.
             They could  involve color-coding < assigning colors to relative state of health), reduction
             of text in graphics, and making graphics map-based. Examples of useful approaches
             recommended by the SAB for EPA review include Ihe State of the Great Lakes
             (Em ironment Canada and EPA. 200]) and Reefs at Risk (Bryant et al.  IW9) reports.

         4.  Where possible,  information in the hihlic Report should be presented in a spatially
             distributed fashion.  The use of national maps, with blow-ups of information \\ilhin
             specific regions, \\ould be very useful. There must be  a balance between providing
             enough data to make graphics informative, but not overwhelming readers with too much
             data.  If done well, the graphics in the I'tih/ic Report can provide a quick overview of
             national status and alsc allow readers to see how their regions fit into the national
             condition.

         5.  In places, the scientific terminology used in the hthlic Report reaches beyond the
             average grasp of the general public.  The SAB recommends that EPA thoroughly review
             the Pnhlic Report to re nove or define these terms.
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     B. Specific Comments in Response to Charge Question 5

        The public document of the draft ROE reads as a distillation of Ihe Technical Document. The
     Public Document can be enhanced by pro\ iding restructured and recornposed information in a
     more easily digestible format. In particular, the graphics in the Public Document should be
     simpler and cleaner, with  the data sources and caveats hyperlinked to the Technical Document.
     The SAB suggests that a graphic approach patterned after the Stale of the Great Lakes document
 5   might be used. This approach would involve a color coding scheme, with all indicators
 c>   presented as hav ing deteriorating (red), mixed/deteriorating (orange), mixed (yellow).
 "•   mixed, improv ing (green), and good (blue) values.  For static indicators, such as area, categories
 s   could reflect increasing and decreasing si/.e instead of value.
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        The i'ublic Report should do more than simplify the Technical Report (although even that
     task was not well-accomplished in the i'nh/ic Report)  It should generally summari/e the state of
     human and em ironmental health today.  It should also point to upcoming problems and discuss
     the tools used  lo understand the health of the planet, from molecular lo ecological levels.

        In developing future versions of the ROE Puhlic Report, the SAB recommends that EPA
     identify and consider target audiences.  The document must educate journalists, members of

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1    Congress, government officials, and other dh erse audiences.  Although the 7'cchniciil Document
2    can be made available on the Internet, the i'nhltc Report should be made available in printed
.>    form.  EPA  should consider including a CD vvilh the 1'nhlic Report containing hyperlinks to
4    Internet websites where more information is available.

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     6.
       REFERENCES
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     Bryant. D.G. el al. 1999. Itcefs at Risk: A Map Based Analysis. World Resource Institute
        hUj)://puhs,s\!';,ori:-pubs  dc^ci'iptioircfni'-PtiblP-OvOi (June 2. 2004)
     Can field. R.L. et al. 2003  Intellectual impairment in children uith blood lead concentrations
         below I Oug per deciliter. AVu England .Journal of AfcJicnu'. 348: 1 5 1 7-1526.

     Carlson. R.E. 1977. A trophic slate index for lakes.  Limnolog\- anJ Oceanography. 22:3C> 1-369.

     Emironment Canada and U.S. EPA. 2001.  State of the C, real Lakes 2i)0 1 . EPA 905-R-OI-003.
         hUp •.•'/bination.y!..!Ayi:so!.i!2< !:!.). (June 2. 2004)
Herkert. J. R.  1994. The effects of habitat fragmentation on mid\\estern grassland bird
   communities. Ecol. Appl  4:461-471.

Herkert. J R.  1995. An analysis of midxveslern breeding bird population irends:  1966-1993.
   Am. Midi. Nat  134:41-50.

McDonald. D.D.. Ingersoll. C.G.. and Berger. T.A. 2000 Dexelopment and evaluation of
   consensus-based sediment i.|uality guidelines for freshuaier ecosystems  Archives of
   Em ironmental  Contamination and Toxicology 39:20-31.

Michigan Department of Environmental Quality.  2004.  DEQ announces establishment of a
   grounduater consenation ad\isory council (GWCAC)
   !A»pi.:-:^>y^ ..•l.-iichiean^o^ d •;.Q.-:!J.,lJiO_7,.7.v.! 3> 33.13 :S6262-'::;UU,lnm! (June 2. 2004 )
Pace. M.L.. and P.M. GrolTman. eds.  1998.  Sitcc-cwcx. Limitations, and l-'rontters in l-l
   Science. Springer. New York.

USGS. 2004.  Groundwater in the Great Lakes Basin: the case of southeastern Wisconsin.
   hup:/. \\:.ualer usus.go\ uinf index.iuni (June 2. 2004)
     Wilcove. D.S.. D. Rolhstein. J. Dubo\\. A. Phillips, and E. Losos. 199S. Quantifying threats to
        imperiled species in the United States. BioScience 48:607-615.

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          Appendix A: Technical Corrections and Comments on the draft ROE

Page number

1-3: Exhibit 1-1   The method for averaging emissions is unclear (ho\\ are PVI2.5 dala and
o/.one data combined'.')  Were the emissions of secondary pollutants such as o/one included, or
\\ere the o/one precursor compounds used'.' There are many questions associated with the
aggregate curve: it should be replaced with curves for individual criteria pollutants. Averaging is
inappropriate here.

I-H: Exhibit 1-4.  AQI is a poor measure when used in this fashion, particularly \\hen essentially
no changes were observed since 1989.  Minor point - the method of plotting percentage implies
error bars.  Is the number of monitoring stations consistent throughout period'.' This figure is
confusing and better omitted.

l-ll:  Exhibit !- total area
   •   Lakes: "<> hardened shoreline
   •   Wetlands: % native plant species (current metric could have a wetland that was not
       physically altered but now totally covered by a monospecific stand of an invasive, and

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       not be considered as "altered")

2-12: Lake trophic stale index usually has a \ ery specific meaning (Carlson. 1977). which
includes TP, clilorophyll a. and transparency. Gi\en the focus on TP here, the use of trophic
state index may be confusing.  Might also note the possible limitations of vising TP. how often
and \\here samples are taken, rnd pros and cons of other parameters

2-14: Coastal wetlands should also include Great Lakes coastal wetlands: the ca. 1500 Great
Lakes coastal wetlands totaling ca.  1 7.01 7 knr were ignored in the document.  It seems as
though the document was written in the year 2000 and then quickly updated with a few citations
in 2001  making ii very much outdated for its content  Huge leaps  regarding these topics have
been made in the past 4 or 5 years.  For example, the U.S. EPA established a national
bioassessment of wetlands working group (BAWWG). much of which deals with establishing
standardi/ed protocols for mla:id wetlands. They also established the Great Lakes Wetlands
Consortium dealing with establishing standardi/ed protocols for measuring the status and trends
of Great Lakes coastal \\eilancs:
hup1..- v. v\ v. .epa yos ,V>v- ov- /W eikinds/baxs w u'
hUjv/'.-\\\\\\ .yc.pra.;\\etiand;;
hup. '.www t,'pq.uo\.- wa'.ei science. bu
2-17:  The figure is not A cry intuitive about how gains (especially ) and losses are partitioned
among the reasons

2- 18:  Section 2.2.3 recogni/es the role that chlorophyll plays in SAV growth and distribution.
Unfortunately, as indicated in the Chesapeake Bay SAV synthesis, suspended solids play an
equally important role in many systems.  Omission of this fact from the discussion and is a
serious shortcoming in the discussion  Furthermore, an indicator for suspended solids is
necessary to describe the condition of the water clarity.

2- 1 9;  The figure needs more explanation for depth of measurement: possibly use SAV cover as
an indicator (based on remote sensing or aerial photography data).

2-19: The water clarity indicator is taken from the EPA Coastal Condition report. There are
serious problems associated this indicator and it should not be used in its current form. In fact.
the use of the indicator is qualified by staling that "the indicator does not account for naturally
turbid conditions" and "low light penetration conditions are not necessarily associated w ilh
impaired aquatic health"   After seeing this qualifier, one is left questioning the value of
information in the report.

The problem is not with the indicator but rather the parameter used as the measure.  It is not
always possible to use the  same level of parameter on  a national scale  This is a situation where
a regional or e\en a local \ alue is necessary to develop the indicator and then the local indicator
is aggregated up to a national  scale.

2-20:  The dissohed oxygen (DO) indicator is taken from the EPA Coastal Condition report.
dissolved oxygen  is a valuable indicator however the values employed to develop the indicator

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 i    are inappropriate for use on a national scale. Bottom DO varies depending upon the degree of
 2    \ ertical stratification and lime of year.  It is widely recogni/ed that in waters from the
 i    Chesapeake Bay north, summer bottom DO should not fall below a site-specific \ alue of
 4    between 3.2 and 3.8 my/I.  This range of values protects aquatic life and is considered safe for
 5    resident biota  Bottom \\ater in the Gull'of Mexico can actually be a little lower and still he safe
 ('    for resident aquatic life. It is misleading to rale waters in these areas less than "good" \\hen they
     are belo\\ 5.0 mg'l but abo\ e the appropriate value.  As with clarity this indicator should be
 x    de\ eloped at the regional le\ el and aggregated up to the National level.  Once again, this
 9    indicator \\as qualified by stating that "The relationship between threshold  values and effects  on
lit    aquatic life is neither \\ell established nor expected to be consistent."  Statements such as this
11    undermine the credibility of the ROF effort and such indicators should be modified  or not
12    presented at all.
13
14    2-2(): Another data gap would be time of day for sampling, as DO exhibits a strong diel pattern.
15
ir>    2-21: Referencing the 15  ppb chlorophyll le\ el as "equal to the restoration goal recommended
17    for SAV restoration in the Chesapeake Bay" is inappropriate and not consistent with the goal
is    recommended by the Chesapeake Bay program.  The value of 15 ppb was taken out of context
19    from table in Batuik. et. al  (2000). The table states emphatically that the recommended criteria
20    for SAV restoration is a specific percent light penetration at a site-specific restoration depth.
21    Chlorophyll le\ els necessary for SAV growth are site-specific and depend upon a combination of
22    suspended sediment and chlorophyll  \ allies that enable the necessary percent light penetration at
23    the site-specific depth of application.  Furthermore the site-specific light penetration value and
2-1    associated parameters are growing season averages. The draft ROE and the National Coastal
25    Condition Report from which this data came does not indicate whether growing season averages
2f>    or raw data scores were used.  Therefore it is not possible to determine if the data correctly
27    match the appropriate duration period.
2S
29    2-22: There is a disconnect between the figure and text: do the data deal with ocean or coastal
     systems'.'  Chlorophyll is not indicative of species composition, so harmful algal blooms (HABs)
     may be missed

     2-23:  Additional considerations - eutrophicalion  The desired indictor is certainly  desired and
     necessary however the presentation of the indicator as shown in the draft ROE does little to
     further  it's development The use of static measures on a seemingly arbitrary scale  needs to be
     revisited and the indicator further refined. The document does qualify the indicator, raising
     questions about its use here.  As correctly noted. "High scores may not be a true measure of
 x    eutrophication"  It  is also pointed out that "there is no strong scientific data to indicate that the
     thresholds used are indeed indicativ e of eutrophic conditions on a region-fax -region  basis."  It
4"    may be possible that trend  data may be more appropriately used here to show an increasing or
41    decreasing trend rather than some arbitrary static measure. It is  strongly recommended that the
42    Agenc) develop this indicator further before incorporation into the future ROH
43
44    While this section discusses eulrophicalion. the reference to "these conditions" including sea
45    grass decline needs the additional parameter of suspended sediment in order to fully capture the
4r.    causes of SAV decline.

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2-24: It seems that the differences between urban and agricultural pressures are also due to the
activities associated \\ith each land use.

2-25: a) The name of indicator may not be representative—perhaps, "urban/developed land
cover" would be appropriate  t) Why restrict this indicator to riparian buffer strip'.' Increasing
urbani/.alion or developed land cox er has impacts throughout watersheds in terms of storm
runoff and nonpoini source pollution, c) Wouldn't percent change over time be a better metric.
assuming there are consistent baseline dates available'.' d) The spatial arrangement of the buffer
/one (either \\hat is left intact or removed) should be considered—contiguous /ones vs. patches
can affect efficiency of riparian /ones. It is not just simply hov\ much, but how it is arranged.

2-26. Similar concerns to abov e. Why limit agricultural land cover to just riparian /one'.'
Perhaps change detection over lime would  be a belter indicator. Consider refining the
agricultural land indicator to type of agricultural land use.  Perhaps subdivide the indicator by
relatively broad categories, such as  row  crops. Concentrated Animal Feeding Operations
(CAFOs). etc

2-29: Sedimentation index.  How often were samples taken per stream1'  Were these one-time
grab samples, integrated over time,  do they include storm events? More information is needed to
assess the indicator.

2-31: Atmospheric  N deposition.  It may be of use to note that although the absolute deposition
rate is potentially useful, the percent of total N that is supplied by atmosphere is also important.
A low rale in a very low N system may be of greater concern than a high rate in a very  high N
system.

2-32: Nitrate concentrations, ll is unclear  when surface water samples were taken, how often.
and whether they include stonr events or are base flow.

2-34:  P also can he very important: the ROE should not focus exclusively on N in estuaries (see
Smith. 1WX Pages 7-4') in: Successes. Limitations, and Frontiers in Ecosystem Science. Pace
and Groffman (editors) How often were samples collected for this analysis'.'  This section
should be cross-referenced to page 2-37 indicator (TP in coastal waters).

2-34: The section on total nitrogen in coastal waters includes Mid-Atlantic estuaries as well as
near shore coastal waters  The use of arbitrary percentiles of distributions without regard to site-
specific issues is misleading  f.'.PA  recogm/es that each  estuary reacts differently to nitrogen
concentrations  The same nitrcgen  concentration would have a greater impact on water quality
in the Chesapeake Bay than it would in the Delaware Riv er.  A more technically defensible
approach to this dilemma would be to use a regionally derived end-point indicator (such as DO)
for evaluations of good or bad. and  then use trend data for the nutrient concentrations as warning
signs to indicate whether the si:uation is getting belter or worse. This is the approach being
employed in the  Chesapeake Bay.  It provides more meaningful information and avoids the
subjective and site-specific issues ofquality.
                                                 41

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 I    2-36: P in large rivers. It is good thai sampling frequency was included, but the threshold for
 2    goal for impairment is loo high
 _>
 -l    2-3H: Sediment toxicity in estuaries.  The indicator of sediment toxicity should be associated
 5    \\ iih the cause of toxicily.  The references used contain information that can identify the causes
 f>    of toxicily. including artificial toxicily due to sample manipulation and handling.  It is not clear
 7    from the draft ROE how arlifaclual toxicily data uas accounted for.  Subdividing the toxicily by
 s    cause would pro\ ide invaluable information to the public and decision makers and improve the
 •'    utility of the ROF.
in
11    2-31.): Hg il is not clear hov\ often data \\ere collected, how many samples, variance, etc. in the
12    data shown
13
14    2-40: The chemical contaminant data shoun reveal nothing about absolute concentrations:
l>    shouldn't  there be an explanation about a threshold or criterion that must be exceeded'.' Are
16    these based on predicted emironmental concentrations (PECs) or dose compliance
17    concentrations (DCCs)'.' Do they exceed drinking uater standards'.''  Also, could these data be
is    shown as  trends from ''J2 to ~W
I"
2n    2-41: Pesticides in streams and groundwater.  Detection does nol necessarily translate into
21    ha/ard. Why not use human health standards for  the limits'.' Why use 0.01 and (). 1 ppb
22    standards'*
23
24    2-43. This seems like an indicator that should be cross-referenced lo the air emission chapter
25    (forNOxandSOj.
2(i
27    2-44: Toxic releases. This is a good  example of how the metric may be quantifiable, but without
2.x    more spatially explicit information, the data can be misleading.  Even if overall release levels
2i>    decline, unless those declines were proportional among all sites and  regions, it is likely that
 o    certain areas may begetting \\orse even if overall trends are better.  In addition, we may be
     reducing in areas that have gross release rales, but still nol meeting ecosystem needs (similar to
     losing  weight in obese people—first fe\v pounds are easy to lose, but unless you lose a lot the
     overall health of a person may not be demonslrably improved).
 4
 5    2-46: Sediment contamination. There is nothing included on Areas  of Concern in ihe Great
 (>    Lakes.  Lois of EPA information are available and should be included.

 s    2-47: Sediment contamination of coastal \\aiers.   This report should recogni/e that for mam
     older cities sediment contamination is largely the result of historical  practices and activities.
40    There are numerous studies in regions such as the San Francisco Bay and the Eli/abeth River in
41    Virginia that demonstrate vastly imprcn ing trends in sediment quality. This data should be
42    mined  and the appropriate indicators dev eloped lo capture these trends.
43
44    2-53: Recreation in and on the \\aier.  This seciion discusses a number of sources of pathogens-
45    in recreational \\aler but lea\es off waste from domestic (urban pels) animals and wildlife.
4f>    Studies from TMDLs are showing (hat animal vvasle is a major source of indicator organisms in
                                                 42

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alt waters.  That animal waste is originating from wild life (sea birds, deer, etc) as well as
domestic pels.

2-54: Section 242.  What are ihe sources of recreational water pollution1' It would be
informative to note in the text thai the sources identified and listed .n this section account for
only 25% of the total reported cases.

2-56: Consumption of fish and shellfish.  It would be useful to point out in this section that the
mercury body burden of some marine species such as swordfish are  natural and. according to
studies cited on the University of California at Da\ is web site, have  been stable for 100 years.

3-3:  Paragraph four: Change "a function of human needs and population density" to "a function
of human needs, wants, and population density."

3-3:  Exhibit 3-1.  In the figure caption, the line is labeled with the units "per acre mile." which
cannot be an accurate measure.

3-4:  U.'S. population density irap.  This is a critical figure. Consider putting this figure in the
introduction. This map should be the  focal point for mam  analyses within this chapter. (Is there a
map with changes in population density to see the drivers of change'.') When phrasing the idea of
"regional" analyses, the draft ROE mentions EPA Regions as the regional unit   Please use the
resolution of the data to guide the definition of regions, and if the regional indicator can be
displayed over the  entire United Stales, use this map as the basis for (he indicator because
population density  ultimately is the key driver for mam  em ironmenlal conditions (but not all)

3-4:  Exhibit 3-2. There's nothing wrong with this map.  but it should be accompanied by a
comparable map that shows the rates  of change in population density. Data clearly  show that the
fastest rales of change have consistently (since the early 1800"s. in fact) been in  the Wesl. a point
that gels lost if only me static measure of density is presented.

3-5:  Exhibit 3-3. list of indicators.  With the tabular listing of the indicators, please  include a
column that references the page upon which it appears  This helps guide the reader through a
long document. As has been mentioned previously, considerable revision is needed in the
questions asked and indicators selected,  li mailers where the different ecosystems types are
located, what their quality and si/e is. and what the adjacent ecosystem types are.

3-7:  Text indicates thai indicators were not identified for protected lands.  Future ROE versions
should be able 10 find indicators for both the extent and quality of protected lands by integrating
data available from main of the sources in the box on protected lands on page 3-8. as well as
non-government organisations such as World Wildlife Fund. The Nature Conservancy, the
Wilderness Society, the Land Trust Alliance and the National Parks  and Conservation
Association.  Most slate governments and NGOs also have reports on the status of public and
private protected lands

3-8:  The box on protected lands should acknowledge that protected  legal status does not always
mean protection in reality  Conservation easements often only protect private land  from major
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 1    development, but do not restrict uses that can significantly degrade water quality and biological
 2    resources.  In addition, the lands put under conservation easement are often already significantly
 3    degraded from a biological and ecological perspective, so the easement only conserves scenic
 4    views.
 5
 6    3-9: Urban -suburban. There is no getting around the fact that land use categories ranging from
 7    urban to wilderness is a continuous gradient and that definitions are arbitrary.  Definitions of
 x    suburban van  and recognition and discussion of the ones used, as on this page, is good. For land
 9    cover and fragmentation very low density (I house/40 acres) is an increasingly used and
10    important category. Although there might be little to do in the short term, the  long term goal
11    should be to classify land use along a continuous gradient of human use density (e.g.. land in row
12    crops is as dense as suburban in terms of habitat loss).
13
14    3-10: Dot map of metro area boundaries and central cities. NRI.  This does not add much
15    beyond the map on page 3-4.  The map on page 3-11 (change) is the one that is useful.
16
17    3-12: Extent of urban/suburban lands.  It seems that the I km2 pixel area as the minimum
is    mapping unit for suburbs used in the Hem/, report will  miss capturing low density housing on a
19    major scale. The age of this data is problematic.  Perhaps data from the U.S. Census Bureau that
20    would indicate the density of housing could be mapped.
21
22    3-14: Extent of croplands. This graphic is a liltle odd in that the dots suggest something like
2?    point occurrences or towns, whereas this really indicates regions of nearly continuous
24    agricultural land.  Please consider alternate mapping form, although the map and the information
25    are good to use.
26
27    3-15: Change of extent of cropland, pastureland, CRP.  This graphic shows little change, yet
28    there has been a massive shift away from pastureland in the eastern tallgrass prairie region of the
29    Midwest that has resulted in a strong decline in grassland associated birds of this region.  This is
 o    the type of national indicator that misses critical changes.  Mapping change in pastureland by
     county would be ideal. A spline fit of the change that was then mapped as isoclines would be
     nice.

 4    3-16: Percent change in cropland.  This is a great map.  The report needs more like it.
 5
 6    3-17: Cropland extent.  Surely the USDA has county level statistics on row crop acreage. This
     would be a variable indicator that changes because of changing cropping patterns and farmland
 8    economies, but it would still be  a good indicator of  an important variable in land use because row
 9    crops receive so many more chemicals than paslureland.
40
41    3-18: Extent of Grassland Shrubland.  This says relatively liltle regarding extent or condition.
42    The graph  is overly complex; stacking the bars would suffice and allow you to assess this at
43    different lime periods to denote  change.  In capturing trends in the extent of the categories, this
44    would be strengthened by a geographical presentation, as there are ecoregions where this is
45    likely to be more important than others.
46
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3-19: Forest extent.  Regional information on amount of forest is fine, and would be even better
if there were graphed data for more than one lime. The text talks about the change in forest
acreage since 1987. It would be nice to show what regions that has occurred in. It is not clear
why public vs. private ownership matters.  Inclusion here seems to imply that there is little the
government can do to protect forests since so much is privately owned. Exhibit 3-10 in current
form does not bring added value and should be deleted.

3-20: Exhibit 3-11. This figure also does not improve understanding of forest extent or quality
and should be deleted.  Data on ihe amount of limber that is certified as being sustainably
harvested from public and private land would be of greater value in lerms of indicating potential
environmental impacts in forests.

3-20: Timber harvest.  If limber harvesl is  disaggregated by forest types, even hardwood vs.
softuood. interesting trends can be observed as U.S. timber harvest increases in softwoods and
decreases in most hardwoods.

3-20: This section requires an indicator on the extent of change, or status of change of plant
community types (habitats) al risk. The USDA has reported on this (Reed Noss. author).
NalureServe (contact Denny Grossman) has plant  community threat ranking information that
would be useful here as well.

3-21: Section 3.1.5 - Human health effects associated with land use. This section is weak. For
example, trends in work related health problems in ihe agricultural and forestry industries would
be a good indicator, it may not work for this report, but it would be an indicator.  So. EPA
should think more about the question, in the broad sense, then write carefully about why what we
might think of as indicators do not work for this report.  There should be a section like this for
each land use category.

3-21: Section 3.1.6 - Ecological affects associated wilh land use. There should be a section like
this for each land use category. This has a very specific introduction lhal suggests that sediment
runoff is a good indicator in general for this. It is  a good indicator for agricultural land.  Thus.
this should be a subsection of agricultural  land.

       Other good indicators:
       Agricultural Lands:
             Change in  sediment run-off potential  (as presented)
             Change in  acreage of organic farms (USDA)
             Change in  streamside buffer strips
             Change in  fertili/er / pesticide sales (as a measure of application)
             Grasslands
             Changes in leased acreage or tola! stocking of federal gra/.ing lands (Bureau of
             Land Management |BLMJ and U.S. Forest Service JUSFS])
             Changes in invasive species spread, or acreages infested (BLM and USFS)
             Changes in grassland-associated bird populations (Breeding Bird Survey |BBS|:
             see papers by J. Herkert on this issue.)
         Forests:
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              Changes in patch si/e (L. Iverson; USFS. Delaware. OH may have statistics, may
              have published them
              Changes in stocking rates of trees (F1A)
              Changes in number of acres listed as fire ha/ards (USFS)
              Population trends in forest associated birds and neotropical migrant birds (BBS).

3-26 and 3-27:  Exhibits 3-15 and 3-16.  Some consistency needs  to be developed in how data
are presented.  There is no logic in presenting some data as histograms and others as line graphs.
Exhibit 3-16 should be changed since it  implies what the values would be for 1992. 1994. and
1996. which are not actually known.

3-27:  Exhibit 3-16. Printing the cumulative °« change is misleading. This is a % change from
1991. but could be interpreted, if not read carefully, to imply and  increasing rate at which  this is
decreasing  If anything, this should report the time interval "« change.

3-28:  Agricultural pesticide use. This is a good indicator, but one has to be very careful here in
that a change, up or down, could rellect  changes in em ironmenial management or impact, but
could also mask effects if the response unit is pounds and the dose changes between chemicals
(i.e.. switching chemicals for a control may alter the pounds, or the impact per pound) That
problem is difficult to solve.

3-3 1:  Pesticide residues in food  This is an important indicator and would benefit from graphic
presentation.

3-33:  Potential pesticide runoff.  Is there an indicator available that does include fruits, mils and
vegetables'.'  There are parts of California. Florida. Michigan and  elsewhere that would  be wholly
misrepresented because they focus on something other than the big grains (Napa valley and
grapes, for example).  It would be excellent if the text could include a few actual pesticide runoff
values and compare them to the potential values to help the reader take the potential estimates
seriously. The text should explain why a potential impact is being used here (and in exhibits 3-
20 and 3-21). while most of the report is focused on actual values (e.g.. because the issue is so
critical and actual data not available at national scale).

3-37:  Section 3.2.5 - Human health effects associated with toxic substances. Organi/ationally.
EPA should put this under Agricultural land.  Data from poison control centers appears to be an
indicator. Why not treat  it as such1'

3-37:  Persistent bioaccumulalive toxic chemicals. EPA has missed a couple of very important
data sets here.  First, it is important to track eggshell data on birds thai were susceptible to DDT
(e.g.. peregrine falcons). Joel  Pagel (USFWS. Los Angeles) would know where these data are.
There is also data on bioaccumulalion in marine birds and mammals  from Alaska. There  is
probably more elsewhere. Keith Miles.  University of California at Dav is knows about these
daia.

3-3X:  Nitrogen runoff from farmlands.  This section seems lo gel disorgani/ed. Creating a
similar construct to Chapters One and Two should help.  Doesn't  EPA track data on factory-

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farms (concentrated animal facilities) and their pollution exports''  This would be a good
indicator here. Not capturing the rise of the concentrated animal facilities and discussing
pollution concerns regarding them is an ob\ ious omission from this report.

3-40 and 3-41:  It \vas difficult to determine which type of \\asle includes automobiles.

3-45: Exhibit 3-28. Aren't there data on this metric from before 2000? A trend on this would
be as interesting as a static measure.

3-47  What is the extent of cor laminated  lands1' It would be helpful to see a geographic
presentation of where  contaminated lands are. The lack of a treatment of contaminated
groundwater is an obvious omission  Something should  be said about it.

3-49: The superfund information. This implies that \\e are gelling a good grip on superfund
sites.  One would \\onder if the problem is getting  better or not because we could be generating
new superfund sites at a rate that exceeds their rate of cleanup. While there has been good
control on this, it would be use ill to report on the year(s) of superfund creation to show that the
de\elopment of new superfund sites is on  the decline

3-52: Exhibit 3-31. This interesting exhibit demonstrates the variation that can occur \\hen data
come from different sources, some of the estimates from different  sources are very close while
some are very different  It helps the reader understand the challenges in preparing this report
Similar comparisons for other ecosystems or issues could be included in the report.

3-52: This says that data on protected lands of different  types and lev els of government do not
exist. The data likely exist, bin ha\ e not yet been integrated in a formal that is readily useful to
EPA

5-12: Extent of area by forest type.  There are classifications by type, and assessments of area by
type.  Here EPA aggregates by type and lumps everything uncommon into "other".  It may  be
better to capture "other" and try to delect which of the lou abundance types are declining.

5-14: Forest Pattern and Fragmentation. The program FRAGSTATS is used specifically to look
at attributes of fragmentation and has been applied by USFS researchers on US forests. Contact
Louis Iverson (USFS. Delaware OH) for details.

5-15: At risk native forest species. "Too little is known about plants" is not really accurate. No
one has aggregated the data, but habitat associations for all plants  is. in fact, known.  The Biota
of North  America Project (BON AP. John  Katies/) manages the floristic database for
NatureServe rarity rankings. They may have this habitat information.  Certainly, this can be
done by region. Also,  why not use the United States endangered species list is for part of this?

5-15: Exhibit 5-X. This does not tell us much.  Try for a geographical presentation of the
distribution of rare species.

5-16: Exhibit 5-9. This needs to be labeled "change in diameter class  si/es for representative

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     forest species". Also, it is quite unclear.

     5-IS: Exhibit 5-11. This is a good indicator.  Can EPA go back and distinguish stress due to
     pollutants from climate, disease and others'.'

     5-l(): Exhibit 5-12. O/one injury. Even bad o/one problems would not manifest much in some
     areas owing to lo\\er industry. Mapping damage would be the ideal.  For example, damage is
     probably highest downwind from major industrial cities  This is good, but would be better with a
     map of the response.
in
11    5-20:
      Carbon storage.  This, of course, makes the most sense as an indicator with global change.
ll is essential to deal with climate change. This is also an area where an international comparison
is possible.

5-21:  Soil Compaction. It would be ideal to restrict this to forests that are actually harvested.
Alternatively, compare harvested and unhan ested stands. This is the sort of indicator that
requires some comparison to background expecied.  This comparison probably would show
forests to be in good condition, bin  il is hard to interpret without some context.

5-22:  Soil Erosion indicator.  "Hie indicator seems like a good idea  However, given the data
limitations, this isn't worth reporting because EPA claims it misrepresents forested lands   EPA
should try to use some estimate of error,  report thai, and provide details about the error estimate
in the appendix B.  Alternatively. EPA should decide il isn't  reliable and discard it.  Il seems
that this should be presented under  "Forest Condition", as should all measures using forest health
monitoring (FHM) data.

5-23:  Processes beyond the normal range of variation.  Although the idea of this indicator is
sound, this does not tell us anything.  If related to climate change, then il might have some
import.  As il stands,  il  seems out of place.

5-24:  Landscape condition. The text stales that "... although  the acreage of some of the types of
forests ha\e changed, none are currently  at risk of being lost."  This is strictly true of the data
presented, but badly misleading.  Certainly there are forest types that are at risk of being lost
(See NntureServe dala). Since EPA lumps all  rare types. EPA only assesses exceedingly
common ones.  This  is a bit like sun eying fast food restaurants to see how often they go out of
business, create McDonalds. Burger King, three others and lump e\ery independent restaurant
into an "other category".  The answer would be that no one ever goes out of business, which
would be erroneous.

5-24:  Biotic condition.  EPA reports that no reliable data set exists on forest stream biota.  This
seems \er\ odd. Certainly there are many indicators of biolic integrity, from the endangered
species list to the NatureSene rankings.  "Precious Heritage" has published lists of the fraction
of species at risk. These data clearly show that aquatic organisms, in general, are in rough shape.
To report that there are no indicators available for forest streams seems to be an overly  narrow
slice of the pie.  If EPA reorgani/es to create biodiversity measures by region, by taxonomic
group, or nationally. EPA would not be boxed into these kinds of statements that, while strictly

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true, are uninformathe and misleading.

5-25:  Farmland Landscapes  EPA is assessing ecological condition of a landscape here. This is
\ery different from oilier sections where EPA assesses condition of an ecosystem. This section
will require indicators of pastureland change and forest fragment change and condition. One
approach would be to create a set of polygons around regions that are dominated by agricultural
lands and then assess landscape condition and biolic condition in these regions.  That \\ould
require de no\ o analysis.

5-26: Right column. 2ml paragraph "Unfortunately, there is no single,  definitive, accurate
estimate of the extent of cropland."  That seems to be a \\eak excuse.  There are many.  They
vary for sensible reasons.  EPA should choose one. justify the choice and use it.

5-26: Why not map the nitrogen leaching into grounduater'.' EPA has a map of groundualer
leaching potential that can be tsed.

5-29: Exhibit 5-17. Despite the fact that soil quality index (SQI) scores from 1994 and 1995
were calculated using "differert calculation procedures and sampling variability" sampling
variability suggests that EPA can estimate a confidence inten al and compare the t\\o. Gi\ en
that this is just one \ ear. any trends are likely to be insignificant. Thus, this reads as if it is due
to index calculation.  The differences between these years are large and consistent.  Pick one year
and report it.  Otherwise, this just lacks credibility.  Frankly, many read as if they were written so
as to best minimi/e credibility  and that is disturbing.

5-31: Near bottom, right column. "... Agricultural lands ..highly managed... no natural
reference exists." The point is not a natural reference: it is trend in condition data.  This is not a
sufficient justification for a lack of indicators.

5-32: Grassland / Shrubland indicators.  EPA identifies stressors (non-native species.
desertification,  groundualer depletion, overgra/ing).  There are indicators of all of these.  They
are likely to be  either regional, or require assembly and analysis on a national level.  Look
beyond the Hein/ report to US DA. USFS. BLM statistics.

5-33: The table on page 5-33 is somewhat misleading. It argues that we need more data, but it
also  fails to get at data that realh do exist, just not pre\ iously published in a national  report

5-34: At risk grassland species.  As in animals,  there is better data  BBS can identify grassland
birds and EPA could examine trends in those species  NatureServe could also identify grassland-
associated species (perhaps even plants using Biota of North America  Program [BONAP]) and
do a better job.

5-35: Declining birds.  EPA misses an important interpretation here   Although native and non-
native birds aren't really doing am thing different (except for the latest time period), grassland
birds have been markedly declining since the 198()'s. That is an  important trend that  probably
reflects the concentration of animals and the loss of pastureland regions.

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 l    5-37: Ecological condition of urban / suburban areas  See R  Primock on plants in Ne\\ York
 2    City and regions. See R Blair on birds and butterflies in San Francisco. The Baltimore and Long
 3    Term Ecological Research Programs (LTER). the urban to rural gradient in New York City, and
 •4    other individual studies provide a means to assess ecological condition within selected urban
 5    environments.
 6
 7    5-38: Summary on urban indicators from prc\ ious chapters. The three final bullet points on the
 s    right are reported in a funny uay. What is the minimum acceptable nitrate concentration, o. l'y If
 9    so. then 97% of the 21  urban streams failed.  If the phosphorus concentration is 0.1. 67% failed
m    (why use "two-thirds" here and 40 and 25 percent above if not to underplay the large number'*).
11    For contaminants. 85% or 100% failed, depending on our standards, which aren't reported.  This
12    is a compelling case that urban surface waters fail our standards for water quality.  Don't sugar
i?    coat it.
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15    5-38 to 5-4(): Index of Biotic Integrity (IBI) indicator.  The report correctly identifies that
16    expected biotic diversity in urban streams is lower than for other traditional free flowing streams.
17    However the IBi scores for all systems were aggregated into one indicator. This aggregation
is    results in a loss of valuable information that could be used to demonstrate the potential adverse
19    relationship between urbani/ation of the landscape and the loss of biologic diversity mstream.
     The aggregation can also be interpreted as indicating that those urban systems could be restored
     to the le\el of diversity that they had before de\elopment.  It is recommended that an indicator
22    be developed to measure the shift of streams from natural to urban (such as the  % of stream
2?    miles as urban) and then segregate the IBI score indicator by stream types This combination of
24    indicators \\ould pro\ ide data on the loss of streams to urban encroachment and the associated
25    loss of diversity as \\ell as provide a measure of the relative health of each type. For example.
2f>    \\hat percentage of urban streams had good or bad IBI>
27
2s    5-39: Exhibit 5-23. Patches of habitat within urban lands.  EPA's interpretation under "what the
2l>    data show" contains a logical error.  The "large" bar is taller in the Northeast than others, bul
     (hese are percentages of "natural lands." Let's say that the Northeast has no natural lands, but
     those that exist are big  (Meadowlands. Central Park. Jamaica Bay). The result would be that a
     relative high proportion of these would be large. e\en though other regions had more large areas.
     and  more small areas (San Francisco, for example). So. it may be better to express as acreage
     and  not a proportion of the regional total.

     5-40 Top left • "...but  their overall condition, nationally or even regionally, is virtually
     unknown." This is just wrong. We know more about urban areas than most. The data are just
     v aried and scattered.

-40    5-42: Right column - "Urban development accounted for an estimated 30%  of all \\etland
41    losses  .". The report  would benefit from an indicator of trends in wetland losses in urban and
42    other areas over the last few decades
43
44    5-43: Top left - Dams, impoundments  There may not be readily available published figures.
45    but there are estimates. The data on what proportion of lakes are oligotrophic lacks meaning
4(i    because we do not know \\hat we should expect  Is this high or low'' Why not use the HP A data

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on impairment'.'

5-45: Extent of ponds, lakes and reservoirs  This is out of place and belongs in the extent
portion of chapter 2. but is also a bit of a nonstarter in that lakes and reservoirs are not to be
equaled, and that error rate relative lo the other data EF'A reports is I ()()% (indicator gaps and
limitations).

5-4(V At risk freslmaler nativ e species. Use the NatureServe data by taxonomic group.
Lumping them together gives on unrealistically  favorable impression of the condition of aquatic
biota because of the large number of some groups of species with relatively low risk.  A large
number of these groups are \ ery threatened, but contain fewer species, and this simply misses
this obvious point.

5-49: At risk freshwater plant communities  Once again. NalureServ e has better data. The
USDA (Reed Noss. lead author) reported on this a few years back.

5-52: Landscape condition.  The Hein/. report may have declined to pick any one of the several
acceptable methods for stream classification  Nonetheless, they exist and EPA should pick one
and use it.

5-52: Left column.  No fish cr.ugln in 16% of streams.  Is this an indicator, or do we not expect
lo catch fish in these streams'.' EPA's next report should make this determination.

5-53: Oceans.  Look to the Pew Oceans Commission for new indicators on the stale of the
Oceans. This is an area where EPA can compare U.S. ocean waters lo International waters.

5-57: Coastal Living habits.  Coral Reefs  There is an abundance of reef information. Check
"Shifting Baselines." They have a website wilh  resources (www.shiflingbaselines.org).  There is
good dala on Pacific estuaries and im asion by Spaninu and (\iulerpti and seagrass beds in
Southern California, as well as invasion in transportation bays,  such as San Francisco Bay
through ballast water. There is an abundance of know ledge on  habitat loss in nearshore
environments along the Pacific.  Know ledgeable people are concentrated al the Bodega Bay
Marine Lab (Don Strong. Susan Williams. Ted Groshol/,...). although others exist. Their reports
are peer reviewed and published. Similar studies ha\ e been done on ihe east coast. This
comment applies throughout this section.

5-64: Ecosystem condition of the nation. Here  is where EPA misses the opportunity lo use
mam good indicators.  EPA  mentions neo-lropical migrants in  the introduction, but then does
not analy/e the  Breeding Bird Survey data on them. Why'.'

5-69: Exhibit 5-42. Please consult the authors of Ihe original  data on this figure. It does not
make sense. The figures a-c.  at a glance, are v. irtually identical (aside from ihe pacific -1998).
We expecl growth to \ ary with climate, but we don't expect climate lo be uniform across the
continent. We expect normal i/ed difference vegetation index (NDVI) lo vary because of cloud
cover or other instrumentation errors,  but we hope lo minimi/e  those  So. what drives ihe \ery
similar patterns across regions'.'  If they were a continuous trend, that would suggest a driver.
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 l    This variability makes one suspicious of whether or not it is real.
 i
     5-72  It is good to see the report attempt to synthesi/e all the information presented for each of
 4    the six Essential Ecological Attributes into some assessment of the national condition for that
 5    attribute across all ecosystems (although no data is presented for t\vo attributes). It would be
 r<    great if Exhibit 5-44 on page 5-75 did not merely have indicator categories in each box. but
 7    instead had some assessment of"condition in each box
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 <>    5-72: Biotic condition. This section is unfairly  disparaging.  There is a \\ealth of information
10    a\ailable that \\as not used in this  report  We know considerably more than this report suggests.
11    and the biotic condition of most systems is considerably worse than this report suggests.
12
i;,     5-74; Vertebrate deformities. Isn't there data on eggshell thickness and birth failure in large
14    birds (pelicans, eagles, peregrine)'.' These \\ould all be non-target effects.  There are likely lots
15    of case studies of non-target effects of herbicides and pesticides.
if.
r    5-76: There are figures on the estimate rates of  harmful algal blooms through lime. Why aren'l
is    these used'.'

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           Appendix B: Specific Comments Referring to the draft Public Report

   A major deficiency in the public document is the lack of qualifying language for some of the
indicators.  The technical defic encies in the National Coastal Condition Report that were
outlined previously in Appendix A should be explained. The Technical Document did provide
qualifying language concerning the limitations of those indicators.  Unfortunately the qualifying
language uas not included in \\\e Puhiic Report.  The i'uhlic Repor< therefore presents an inflated
sense of the accuracy of these indicators. Lack of qualifying language for these indicators is a
serious omission.

Page number

i:  E\eculi\e Summary.  The report does not meet one of its slated purposes, communicating how
to better "manage for environmental results",  SAB does not think that the report should focus
on this issue.

ii:  The cleaner air summary has too much focus on ho\v quality has changed, and not enough
description of the what our current air quality is

iii: The average reader \\ill noi understand the opening statement:  ihat v\e know a great deal
about the condition of \\ater at the regional, state, tribal and local \s\ els. but we don't know the
national status.  The average person would  ask \vhy'.'

iv:  The opening box summary talks about EPA's role in protecting land, and not about the status
of land (in contrast to the air and water opening boxes).  The report should not talk about EPA's
role here.

x-xi:  The hihlic Report could use lots of graphics like exhibit 1-2. that put data in a geographic
context. Unfortunateh ,  with the exception of the Great Lakes pie  chart, the data presented on
these two pages have nothing (o do with the maps on which they are placed.

1-2: The section opens with the question "how clean is the air we breathe'.'"  The apparent
answer "cleaner than 3 decades ago", does not answer that question.

1-6: Pollution is not only impairing visibility in national parks; it affects v isibility in cities too.

2-6: Overall Condition of estuaries and Great Lakes.  This presentation used the results of the
National Coastal Condition Report that had numerous qualifiers concerning the accuracy of the
indicators as true indicators.  The absence of any of this language in the presentation of the report
seriously undermines the credibility of the I'ublic Report.

Pg: 2-7: Dissolved Oxygen and Clarity.  The manner in which these indicators  were developed
undermines their utility as incicators of "good or poor" conditions. The Technical report
actually provided information about this shortcoming, but the omission of the DO and clarity
qualifier in the I'ublic Report  calls into question the objectiv ity and utility of this  report.

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 I    Pg 2-1 1 : What are the ecological effects associated \\ith impaired waters'.' This section deleled
 2    the discussion in tiie technical report that recogni/es that urban waterways have reduced
 3    diversity due to their very nature, and that it is unreasonable to expect urban waters to have fish
 •4    and benthic diversity comparable to more pristine waterways.  The htb/ic Re/>on missed a
 5    \al liable opportunity to educate the public about the impact that urbani/ation has on aquatic
 c>    systems. Prevention is the key to this problem and  this discussion could have played a major
     role in that activity.
 s
 •»    5-5: Seems like the draft ROE is "mixing apples and oranges". For most ecosystems, the focus
in    is on area of overall system, but for coastal the draft ROE includes biotic elements (SAY): this
1 1    could create confusion due to lack of consistency.
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i.>    5-6: column  one has switched from ecosystem type to land cover type: was this intentional?
it    Why are wetlands  broken out from fresh waters in (his table, but aggregated with it in text'.'
15
k<    5-7: Define what is meant by imperiled or critically imperiled. Does this have a quantitative
1 7    component'.'
is
li>    5-7: Biotic Condition .  The EPA missed an invaluable opportunity by not pro\ iding a
2n    discussion of the status offish stocks and the role that fish stocks have on water quality. The
21    Essential Ecological Attributes currently focus on the role of human management acliv ilies ha\e
22    on \\ater quality through the alteration of the physical and chemical aspects of the environment.
23    However it is well established that human management of the  biological systems (fisheries) has a
2-1    role affecting water quality.  Reductions of filter feeders and gra/.ers though harvesting adversely
25    affects water quality, and this role needs recognition in the ROE.  The 1'nhlic Report provides an
26    excellent opportunity to educate the public as all aspects of the environment and our impact on it.
T7
2s   5-9: Consider using ppm instead of rng L - it is easier to understand for lay audience
2<>
     5-10: Use a figure to explain role of solar energy instead of text.

     5-1 1: Exhibits 5-7 and 5-8 should be belter coordinated to use same scale of units, and \\ith
     better explanation of \\hal yield and load mean. Load, in particular, can confuse the general
     public, so care must be taken to differentiate that high loads may be due to discharge.
     concentration, or both.  Is the high load in the Mississippi because of its discharge or
     disproportionate concentrations'.'

     5- 1 X: The parallel \\ ith GNP or a similar macroeconomic index is not yet appropriate. To have
     a macroecological index, one would need to aggregate at a higher level than is being done here
in   perhaps take the indiv idual indices for each ecological condition and sum. or weight
-il   appropriately, to develop an entirely new index.
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