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                                                                                       NHEERL-COR-2369A
NHFFRT m* ^fiQA TECHNICAL REPORT DATA
Htuiiiiu, IAJK -ijoyA (Please read instructions on the reverse before complef—' PR9000.in?q44
1. REPORT NO. 2.
EPA. 600/A-99/096
4. TITLE AND SUBTITLE Going against the current: expanding the inland aquatic
monitoring culture of federal and state agencies.
7. AUTHOR(S) Anthony R. Olsen
9. PERFORMING ORGANIZATION NAME AND ADDRESS
US EPA NHEERL
200 SVV 35lh Street
Corvallis, OR 97333
12. SPONSORING AGENCY NAME AND ADDRESS
US EPA ENVIRONMENTAL RESEARCH LABORATORY
200 SW 35th Street
Corvallis, OR 97333
3- niiinuiiiiiiiiiiiinn
5. REPORT DATE
6. PERFORMING ORGANIZATION
CODE
8. PERFORMING ORGANIZATION REPORT
NO.
10. PROGRAM ELEMENT NO.
1 1 . CONTRACT/GRANT NO.
1 3. TYPE OF REPORT AND PERIOD
COVERED
14. SPONSORING AGENCY CODE
EPA/600/02
' 15. SUPPLEMENTARY NOTES:
16. Abstract: My interest concerns the design of lake and stream monitoring programs implemented by federal and state
agencies in response to the Clean Water Act.  Past, and most current, monitoring designs select sites using judgement criteria.
Such designs provide valuable data for assessing impacts of point source discharges. The Clean Water Act also requires a
national assessment of all waters within the United States. The assessment is accomplished by compiling information obtained
from state monitoring programs.  Such data do not provide a defensible assessment. An impetus for change began in the late
1980's. The U.S. Geological Survey and the U.S. EPA initiated two independent programs: the National Water Quality
Assessment Program (NAWQA) and the Environmental Monitoring and Assessment Program (EMAP). These programs use two
different scientific approaches.for monitoring.  In addition, states have competing monitoring requirements.  When the academic
community's scientific research perspective is added, the result is a natural adversity among the groups. The paper discusses
the underlying cultural conflicts associated with monitoring and present  mechanisms that  have been used to expand the culture,
especially with states.
1 7. KEY WORDS AND DOCUMENT ANALYSIS
a. DESCRIPTORS
Environmental monitoring, Survey design,
Social culture of organizations, Clean Water
Act, Probability sampling
18. DISTRIBUTION STATEMENT
b. IDENTIFIERS/OPEN
TERMS
ENDED

19. SECURITY CLASS
20. SECURITY CLASS
(This Report}
(This page)
c. COSATI Field/Group

21. NO. OF PAGES: 8
22. PRICE
          EPA Form 2220-1 (Rev. 4-77)   PREVIOUS EDITION IS OBSOLETE

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               GOING AGAINST THE CURRENT: EXPANDING THE INLAND AQUATIC
                   MONITORING CULTURE OF FEDERAL AND STATE AGENCIES
                          Anthony R. Olsen, US Environmental Protection Agency
                    Western Ecology Division, 200 S. W. 35th Street, Corvallis, OR 97333
 Key  Words:  Environmental  monitoring, survey
 design, social culture of organizations, Clean Water
 Act, probability sampling,

 ABSTRACT

     My interest concerns the design of lake and stream
 monitoring programs implemented by federal and state
 agencies  in response to the Clean Water Act.  Past, and
 most  current, monitoring  designs select  sites  using
 judgement criteria. Such designs provide valuable data
 for assessing impacts of point source discharges. The
 Clean Water Act also requires a national assessment of
 all waters within the United States. The assessment is
 accomplished by compiling information obtained from
 state monitoring programs.  Such data do not provide a
 defensible assessment. An  impetus for change began in
 the late 1980s. The U.S. Geological Survey and the U.S.
 EPA initiated two independent programs: the National
 Water Quality Assessment program (NAWQA) and the
 Environmental  Monitoring and  Assessment  Program
 (EMAP). These programs  use  two different scientific
 approaches  for  monitoring.  In  addition, States have
 competing monitoring requirements. When the academic
 community's scientific research perspective is added, the
 result is a natural adversity among the groups. The paper
 discusses the underlying cultural conflicts associated with
 monitoring and present mechanisms that have been used
 to expand the culture, especially with states.

 Introduction

     The United  States interest in water quality began in
 the late nineteenth century with a now obscure law called
 the Rivers and Harbors Act  of 1899. This law remained
 the principal basis for protection of water quality until the
 mid-twentieth century. The Water Pollution Control Act
 of 1948 (P.L. 80-845) provided the first federal funds for
 state water  pollution  control  programs and started
 subsidies for the construction of sewage treatment plants.
 A key aspect was that all the details were left to  the
 states. This process continued under the Federal Water
 Pollution  Control  Act of  1956 (P.L.  84-660) with
 increasing commitments in 1961 (P.L. 87-88), 1965 (P.L.
 89-234), and 1966 (P.L. 89-753).  For the most part no
enforceable standards were imposed. In 1965 Congress
created   the  Federal   Water   Pollution   Control
Administration and required the states to develop water
 quality standards  for interstate  waters.  Adlcr ct. al.
 (1993) state that "even then, enforcers had to prove that
 a particular polluter caused violations of these instream
 standards - no small task given the primitive state of
 water quality monitoring and science and the crowd of
 dischargers to most polluted waters."

     An event on June 22, 1969, dramatized the state of
 water pollution  at the time - the Cuyahoga River in
 Cleveland, Ohio, burst into flames, fueled by oil and
 other industrial wastes.  In  1972, Congress passed the
 Clean Water Act, overriding President Nixon's veto.
 Significantly,  the act  begins  with  a statement of
 underlying visions and goals. Congress declared, "The
 objective of this Act is to restore and  maintain the
 chemical, physical,  and  biological  integrity  of the
 Nation's waters." For the first time, Congress framed the
 issue in  terms of the entire aquatic ecosystem, not just
 chemical pollution. The Act also insisted that we restore
 and maintain aquatic ecosystems, and that we actively
 protect waters that were currently clean.   The Clean
 Water Act was significantly modified in 1977 and 1987.
 Section 305(b) of the Clean Water Act mandated that the
 states monitor their waters and report their  findings to
 EPA.  EPA was required to submit the findings in a
 National Water Quality Inventory to Congress every two
 years. Hence a basis exists in the Clean Water Act for
 national statistics on the status of aquatic ecosystems.

 Aquatic  Monitoring 1960-1988

     Monitoring of lakes  and rivers during the period
 1960-1988 can be characterized as follows.  First, site
 selection was dominated by judgment selection of fixed
 sites.   Since  states were  directly  responsible  for
 monitoring, their monitoring programs reflected their
 major priorities.  Consequently, compliance  monitoring
 of  point source  discharges constituted  the primary
 objective of monitoring. Compliance monitoring initially
 focused on monitoring water quality in streams or lakes
 near point discharges. Subsequently, dischargers were
 required  to monitor effluent  directly,  prior  to  its
discharge.  Regulatory monitoring related to drinking
water was also a focus. Public and private drinking water
facilities were required to monitor the chemical quality of
their finished water.

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     Beginning in 1972, the states also were required to
 provide  reports to US  EPA  for its biennial report to
 Congress on the status  of aquatic waters in the United
 States, informally termed the 305(b) report. The 305(b)
 report provides estimates of the number of stream miles,
 lake area, and estuarinc area that meet specific designated
 beneficial  uses.  Designated uses  include aquatic  life
 support, fish consumption, shellfish  harvesting, drinking
 water supply,  primary contact recreation swimming,
 secondary contact recreation, agriculture,  ground water
 recharge, and wildlife habitat.    Section 305(b) of the
 Clean Water Act requires that the states biennially survey
 their water quality for attainment of designated beneficial
 uses.  EPA's Office of Water provides  guidelines to
 states on the information  to be reported and also funds
 monitoring by the states (USEPA  1995).  The process
 over the years can best be described as quasi-laissez-faire
 with EPA providing general   guidelines  to States.
 Consequently,  the national report is a collection  of
 information that can not be easily compared across states
 or from one report to the next.  Adler et. al.  (1993) report
 that "the percentage  of waters assessed varies wildly
 among states", rarely is  sampling done.

     In 1987, the Clean Water Act increased its focus on
 the  National Pollution  Discharge  Elimination System
 (NPDES)  permitting  process.   These  permits   are
 supposed to be based on a detailed total maximum daily
 load (TMDL) and wasteload allocation, which take into
 account information about all sources of a pollutant into
 a given receiving waterbody.  Section  303(1) institutes a
 listing of all state waters that fail to meet water quality
 standards or otherwise do not support designated uses.
 The TMDL process requires monitoring data to support
 its implementation and has been the  cause of significant
 monitoring activity by the states.

     During this  period, state  agencies and  US EPA
 focused on monitoring the impacts  of point sources to
 aquatic systems, i.e., compliance monitoring. This period
 can  be characterized as a period  of inadequate  and
 inconsistent monitoring at all  levels.  Many individual
 point source discharges  were adequately monitored  for
 contaminants.

 Impetus for Change

    In the late 1980s several changes in our approach to
 monitoring began to take place in the United States.  One
 major change was an increased interest in the biological
or ecological condition of lakes and streams.  Another
was the realization that it was not feasible to monitor all
lakes and rivers in the United States. This realization was
 partly the result of states being faced with declining funds
 with which to conduct monitoring.

     Two major federal initiatives had their beginning in
 the late 1980s: the National Water Quality Assessment
 program (NAWQA) and the Environmental Monitoring
 and Assessment Program (EMAP).

     In  1991, the U.S.  Geological  Survey began  the
 NAWQA program.  NAWQA provides consistent and
 comparable information on water resources in 60 of the
 largest  and most important hydrologic systems in  the
 United   States.    It  covers  about one-half  of  the
 conterminous United States and approximately 60-70% of
 national water use. The program focuses on 20 units at
 one time with each unit proceeding through three phases:
 initial planning and retrospective analysis of existing data
 (2 years), intensive data collection and analysis (3 years),
 and report preparation and low-level assessment activity
 (6 years).  One third of the 60 units are in the intensive
 phase at any given time. The objectives of NAWQA  are
 (Helsel  1995):   "To describe  current water-quality
 conditions for a large part of the Nation's freshwater
 streams, rivers and aquifers.  To describe for those areas
 how water quality is changing over time.  To  improve
 understanding of the primary natural and human factors
 that  affect water-quality conditions."  The  stream
 sampling design focuses on selecting sites to represent the
 major  land  uses  and  physiographic regions.     A
 combination of fixed sites and synoptic surveys are used
 to collect data appropriate to the building of relational
 models  of water-quality and environmental factors. The
 models  form the basis for generalizing the results to entire
 geographic regions. No attempt is made to estimate the
 stream length that meets specific designated uses or other
 criteria.

    EPA's Environmental Monitoring and Assessment
 Program (EMAP) began in  1990 as  an interagency,
 interdisciplinary program that  would contribute  to
 decisions on environmental protection and management
 by integrating  research,  monitoring, and assessment.
 EMAP's goal was to monitor and assess the condition of
 the ecological resources of the United States.   To
 accomplish this goal EMAP proposed (1) to estimate the
 current status, trends, and change in the extent of selected
 indicators of the Nation's ecological  resources on a
 regional basis with known confidence  and  (2) to seek
 associations among selected indicators of natural and
 anthropogenic stresses and indicators  of condition  of
 ecological resources. The intent was to provide annual
 reports on regional status. (Messer et.  al. 1991).  The
program was designed to address the information needs
 for EPA's relative risk paradigm (Thornton et. al. 1993).

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 EMAP has evolved into a research program to develop
 the tools necessary to monitor and assess the status and
 trends of national ecological resources (USEPA 1997).
 EMAP's  research  goal is  to develop  the  scientific
 understanding for translating environmental monitoring
 data  from  multiple spatial and  temporal  scales  into
 assessments of ecological condition and forecasts of the
 future risks to the sustainability of our natural resources.
 A major part of the program  is the conduct of large-scale
 regional  geographic  studies.   These studies, lasting
 approximately five years enable researchers to investigate
 new monitoring methods at  these scales and to provide
 monitoring data that are used in regional assessments of
 the status of the ecological systems. Major emphasis now
 is  given  almost  exclusively  to  inland  aquatic  and
 estuarine ecosystems and to landscape analyses.

     In 1992  the  Intergovernmental  Task Force  on
 Monitoring Water Quality (ITFM) was formed to review
 and   evaluate   water-quality  monitoring  activities
 nationwide and to recommend improvements. The ITFM
 issued a strategy for improving water-quality monitoring
 in 1995 (ITFM 1995).  It concluded that "it has become
 clear that monitoring activities need to be improved and
 integrated better to meet the full range of needs more
 effectively  and  economically."    The   committee
 determined that a new approach to monitoring is required
 to target water-pollution-control resources to prioritize
 concerns  and to evaluate the effectiveness of actions
 taken  to prevent or remediate problems. In particular, a
 better balance of ambient and compliance monitoring was
 identified  as  a  need.   Their  recommendations  are
 organized around the topics of working together, sharing
 data, using comparable methods, designing monitoring
 programs, and  reporting findings.   They identified
 institutional and technical changes as necessary parts of
 a "strategy for nationwide, integrated, voluntary water-
 quality monitoring."

    In July, 1995, the National Science and Technology
 Council through its Committee  on  Environment  and
 Natural Resources created the Environmental Monitoring
 Team with the charge "to develop a national framework
 for  integration  and coordination of environmental
 monitoring and related research through collaboration and
 building upon existing  networks  and  programs."  The
 team proposed a conceptual framework described by
 CENR (1997). The framework proposed three levels of
 monitoring: intensive monitoring and research  sites,
 national and regional resource surveys, and complete
coverage programs (mainly remote sensing based).  At
each level existing programs were to be coordinated to
meet the  requirements.   Neither ITFM nor CENR
proposed the development of a  new monitoring strategy
 to replace existing, diverse, overlapping, and incomplete
 programs.

 A Preferred State for Aquatic Monitoring?

     Aquatic monitoring encompasses many different
 measurement  activities on  multiple types of aquatic
 ecosystems.    Ecosystems  include  lakes, reservoirs,
 streams, rivers, estuaries, coastal waters, wetlands as well
 as their associated riparian areas and upland watersheds.
 Monitoring may be intensive (e.g., daily at a single site),
 watershed (multiple sites with frequent measurements), or
 national (e.g., large number of sites measured annually).
 Aquatic monitoring involve only a single contaminant or
 may encompass a wide suite of ecological measurements.
     The  ITFM  report  gives  a   general  set  of
 recommendations  for  aquatic  monitoring  within the
 United States.  It does not propose a specific vision nor
 specific organizational structure for monitoring. In that
 sense, it  falls  far short  of outlining a  federal/state
 environmental  monitoring   statistical   framework.
 Although a  number of changes have been made in the
 Clean Water Act, the basic requirements for monitoring
 have not changed much during the last 25 years. Ambient
 and compliance monitoring have always been part of the
 Act.   However,  the  historical  focus  has  been on
 compliance  monitoring.  Section 305(b)  of the Clean
 Water Act requires EPA to complete "a description of the
 water quality of all navigable waters in such State during
 the preceding year" and " an analysis of the extent to
 which all  navigable waters of such State provide for the
 protection and propagation of a balanced population of
 shellfish,  fish,  and  wildlife and allows  recreational
 activities in and on the water."  Ambient monitoring that
 would  enable  quantitative,  scientifically-defensible
 estimates  as required by Section 305(b) has never been
 achieved.  This difficult task requires either complete
 coverage of all  navigable waters or a probability survey.
 Equally important is the requirement that monitoring must
 include more than water column chemistry, contaminants
 in fish tissue, and contaminants in sediment. Monitoring
 must  include   water  column  physical  properties,
 biological measures, in-stream habitat, riparian habitat,
 and upland  (or  watershed)  habitat  to   meet  the
 requirements.

    Prioritizing the monitoring effort is a daunting task.
 As in any statistical reporting effort, priorities must be set
 to meet the most important information needs of society
within the budgets  available. No organized effort to do
this appears to  be  taking place.  The National Water-
Quality Monitoring Council (NWQMC) was established

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as the successor to the 1TFM in 1997.  It is charged with
enhancing the collaboration and coordination of water
resource quality monitoring at the national, state, tribal,
and local levels, as well as similar activities involving
business  and  industry,  academia,  agriculture, and
environmental groups.  Its role is described on their web
page: http://h2o.usgs.gov/public/wicp/nwqmc.hlTnl.  No
indication is given that a goal is to develop a federal/state
environmental  statistics  framework, except as it may
develop through voluntary cooperation. The  terms of
reference for the NWQMC do not include any reference
to statistical survey design, or even the importance of site
selection in monitoring.

     What would be a preferred state for inland aquatic
monitoring in the United. States? Should we ex-pect to
have a federal environmental statistical agency with data
collection, analysis and reporting responsibility such as
we  have for national  agricultural economic statistics,
economic statistics, transportation statistics? Would it be
cost-effective to centralize all inland aquatic monitoring
through an integration of monitoring conducting by a
single federal agency and a single  agency within each
State?   Should an entirely new monitoring effort  be
planned, with the transition of existing programs into the
new program? How closely linked should monitoring be
to providing information for supplemental accounts tc the
National System of Accounts?  At this time, I do  not
believe a preferred state for monitoring exists.

Changing the Culture

     Since 1990, several  efforts mentioned above have
begun to change the culture of aquatic monitoring  in the
United  States.   How have these efforts fared?   What
resistance have they faced? Are they coordinated? Are
they making a difference? What is the prospect that the
United States will have a scientifically defensible national
water quality report in the near-future? I consider these
questions  below  under  the  topics   of statistical
methodology,  statistical  education, and sociology  of
organizations.   My discussion focuses on statistical
aspects,  while  ignoring  equally  important  areas   of
ecological science, information management, and others.

     Statistical Methodology

     My  discussion of statistical methodology will be
limited to site selection issues. Other areas are important,
such as response design (Stevens and Urquhart 1999) and
determining cause-effect. However, much of the change
in culture centers on site selection.
stream  monitoring  in the  United  States  has  been
conducted through fixed station networks.  Note that our
use of the term lake will refer to both natural lakes  and
reservoirs and that our use of the term stream will refer to
all streams and rivers fromsmall headwater streams to the
great rivers such as the Mississippi. Periodically, USEPA
has  conducted national or regional  probability-based
surveys of  lakes and streams, but  in most cases  the
surveys targeted a subset of lakes or streams. To the best
of my knowledge, no state had integrated  a probability-
based survey as part of their basic monitoring program
prior to 1990. The book used in a prominent monitoring
design  course, taught  at  least annually,  includes no
reference to probability-based survey design  for  site
selection (Sanders et. al.  1983). The authors state  that
locating a site consists of selecting a river reach to
sample, locating  a specific site within the reach,  and
selecting representative locations on the cross-section at
the site.  They focus on the hydrology of the stream
network and  known  locations of point sources  as
important factors in selecting the reach and site within the
reach.  Their network design approach does not appear to
have an objective to provide quantitative estimates of the
status of aquatic resources summarized for states or other
geographic delineations.

    EMAP  proposed a radically different approach to
sampling lakes and streams (Messer et. al. 1991).  As
stated previously, a primary objective was to produce
quantitative starur  and trend  information over  large
geographic  regions.   It  was  based on  a  two-stage
probability-based survey design. The first stage consisted
of a systematic area sample of 40 km2 hexagons.  The
second stage  constructed a list frame of all lakes or
streams within each  hexagon.  A  complex unequal
probability weighting and spatial clustering algorithm was
used to spatially disperse  the sample and  select  an
expected one site per hexagon (Overton et. al. 1990). The
entire design used a newly created discrete global grid
(White etal 1992). EMAP attempted to communicate  the
monitoring  design  to  the  monitoring and  ecological
community but with limited success. It was too much of
a cultural change for the current way of doing business.
Rather than  recognizing the overall benefits of EMAP
survey design, the details of the design became the focus.
The statistical community also expressed concern about
the  design and how well it would  meet  the needs of
EMAP.  Some of their concerns were justified.  The
design required additional research on statistical methods
before it could be supported theoretically. Since then, the
necessary theoretical foundations for probability-based
    With rare exceptions, the entire history of lake and

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survey designs of lakes and streams has been completed
(Stevens  1997, Olsen and Stevens  1998, Stevens and
Olsen 1999, Stevens and Urquhart 1999).

     New theoretical developments  were  necessary to
address   the  problems  presented   by  large-scale
probability-based survey designs for lakes and streams, as
well as other ecological resources. The wealth of survey
methodology  and  experience  that  exists for sampling
hum;tn  populo''}ns and institutions does not exist for
ecological resources.   Finding  or  extracting suitable
sampling frames is only beginning to  occur.  Although
EMAP  relies heavily  on  design-based  estimation
methods, over time model-based methods will almost
certainly become more important. Since spatial location
 is such an integral part of ecological resource monitoring,
all  statistical methods must incorporate the spatial
dimension.

     Statistical Education

     The  inland aquatic monitoring community has a
history of fixed-station, judgement-based site selection.
Data from these sites are summarized routinely as if they
were a  simple  random sample, i.e., sample  means,
proportions, variances are calculated.  If scientifically
defensible national estimates of the status of lakes and
streams  is to  be attained (Paulsen et. al. 1998), this
culture  must be changed.  What steps can be taken to
change  the culture?

     Most  members of the  inland aquatic  scientific
community have an introduction to statistics as part of the
undergraduate or graduate education.  Typically, they
have taken one or two courses for non-statistics majors
and a number of years has elapsed  since  taking the
courses. They understand the basic concepts of statistics,
or  at least know  they should be  concerned  about
particular  issues.    Most  have  been  exposed  to
experimental designs and the need for randomization. It
seems that all have heard that stratification is critical - so
much so that stratification is used excessively even when
it's  not necessary.   Seldom do  they  remember being
introduced to  probability-based survey design.  If they
have, they know simple  random sampling, stratified
random  sampling,  and systematic   sampling.    My
conclusion is  that  the academic  community (statistics,
environmental science, ecology) must emphasize survey
sampling more, so that the next generation of scientists
has a broader base of statistical methods.

    EMAP seriously misjudged the  gap  that existed
between the design they proposed and the knowledge of
the monitoring community.  Based on our experience
over the past ten years, we have found that the gap can be
closed by acknowledging that statistical education is part
of the process of designing a monitoring program.  No
textbook  exists  that  focuses on  survey  designs for
ecological  resources,  particularly  aquatic  ecosystems.
Useful references are Gilbert (1987), Thompson (1992),
and Schreuder et. al. (1993).

     In 1994 EMAP began  an effort, called  Regional
EMAP, that contributes to the statistical education of the
monitoring community. Regional EMAP, or REMAP, is
a program where every two years each of the ten  EPA
Regions is asked to participate in a monitoring study of
an aquatic resource. EMAP provides (partial) funding for
the study, but the Region selects the study area, resource,
and objectives for the study. EMAP also contributes its
research staff time to help the Region formulate the study,
determine measurement protocols, and, most important,
select a survey design. EMAP not only works with the
study team to select the probability-based survey design,
but actually selects  the sample.  An integral part of the
process are discussions concerning the clarity of the study
objectives, explicit definitions of the target  populations,
importance  of  the  sampling  frame,  concepts   of
probability-based surveys, and importance  of tying the
statistical analysis to the survey design. Over 100 studies
have begun under this program, involving  hundreds of
individual researchers and government agencies.

    Sociology of Organizations

    Changing culture always involves  the sociology of
organizations.  What organizations are directly involved
in the process?   For inland  aquatic resources,  the
principal organizational entities are EPA Office of Water,
EPA  Office of Research  and  Development,  EPA
Regional  Offices,  State  monitoring  agencies,  U.S.
Geological Survey, ecological  academic  community,
statistical academic community. Other federal agencies
and  professional organizations are also  part of  the
community, but  the above  illustrates the breadth  of
organizational entities.

    Three organizations within EPA actively participate
in pursuing the status of aquatic resources in the United
States: Regional  Offices, Office of Water, and Office of
Research and  Development.  Regional  Offices work
directly with the states to implement the Clean Water Act
monitoring  requirements.    Office  of  Water  has
responsibility for compiling the National Water Quality
Inventory report  to  Congress and  develops the federal
regulations and guidelines for state monitoring.  Office of
Research and Development (ORD) conducts research in
support of the Agency's mission to restore and maintain

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 the chemical, physical, and biological  integrity of the
 Nation's waters. EMAP is an ORD initiative. A change
 in the culture of aquatic  monitoring  must have  the
 agreement of the Office  of Water.    As  in  any
 organization,  priorities differ among  the three EPA
 offices. ORD's EMAP program was a radical initiative
 that  could have been viewed as a direct threat to  the
 current monitoring environment established by the Office
 of Water. Any radical change implies a measure of chaos
 during  implementation.   Keeping  a  firm handle on
 communications among the EPA offices would be critical
 to its success. Within ORD the budget for EMAP would
 likely have a significant negative budget impact on other
 research programs, given the likely constant budget of
 ORD. These and other considerations make changes in
 culture extremely  difficult within an agency unless the
 change is mandated by Congress.  This was not the case
 with EMAP.

     EMAP and NAWQA, a program of USGS, began
 about the same time.  Both stated that their objectives
 were to measure  the status and  trends of the  inland
 aquatic resources.  Confusion arose about the programs
 and   a  perception that  they  duplicated each  other
 developed.   Although EMAP was intended to be an
 interagency effort, the agencies  found it difficult  to
 collaborate.

     EPA regional  offices and state monitoring agencies
 have enormous investments in compliance and TMDL
 monitoring.    Although the  states are  required  to
 contribute to EP A's national report, most do not view that
 reporting as critical to meeting their primary monitoring
 objectives. EMAP focused on obtaining data to meet the
 requirements for the national report. Even more critical,
 the  monitoring was designed to provide national and
 regional estimates, not state-level estimates. Many states
 did not see what benefit EMAP would bring to them.
 EMAP envisioned a future where the sample size and
 survey design would address state-level concerns about
 status and trends.  However, the cost to do so prohibited
 proposing a state-level program.  The consequence was
 that states found it difficult, if not impossible, to support
 the change in culture.

    Some  in the  academic  ecological community are
 involved directly or indirectly; some are not.  A typical
 view is that monitoring is not research and consequently
 does little to further our understanding of the aquatic
 ecosystems.  Most ecological research occurs in small
 watersheds and in limited geographic extent. The studies
 appropriately use concepts associated with experimental
design.  The measurements  focus more on ecological
processes and can be labor and time intensive; variability
 is a major factor.  Consequently, when a large-scale
 monitoring program, such as EMAP, states that it will
 make biological measurements over large geographic
 areas and  generally restrict the  measurements to be
 obtainable within a single day, the community is naturally
 apprehensive. Their concerns arc legitimate and must be
 addressed as part of the research necessary to implement
 a monitoring program.  EPA, like most federal agencies,
 actively solicits  external peer review.  EMAP  was no
 exception and initiated a review by  the National Research
 Council (NRC)  during the development and planning
 phase of the  program.  Their final report (NRC 1995)
 concluded "that  EMAP's goals arc laudable. However,
 because achieving the  goals of this ambitious program
 will require that EMAP successfully meet many difficult
 scientific, practical, and management  challenges,  the
 committee continues to question whether and how well all
 these goals can be achieved." They were concerned that
 the design was at too coarse a scale in time and space to
 detect meaningful changes, that further  development of
 biological indicators of ecological health was required,
 and that the retrospective monitoring approach may  not
 match  needs of assessment.    From  a statistical
 perspective,  they  recommended stratified  random
 sampling  by  ecoregion,   linking with  site-specific
 intensive research study sites,  and  undertaking more
 power  analyses  of ability to  detect change.  These
 concerns can not be dismissed and were not dismissed by
 management within EPA.   The social culture of EPA
 responded to the reviews, in some cases as providing
 guidance on how to improve the program and in others as
justification for reducing or eliminating  it.  Peer review
 panels must understand the social culture of an agency in
 terms of how it interprets external reviews.

     The academic statistics community  raised many of
 the  same  scientific  concerns   as  their  ecological
 counterparts.    Although  the  ecological  community
 questioned  the basic use  of probability-based  survey
 designs, the statistical  community accepted that basic
 concept. Their concerns focused on the particular survey
 design choice. What was the basis  for EMAP's decision
 to use a systematic grid area sample for the first stage?
 Would the design provide the required precision? Why
rely on design-based estimation, rather than incorporate
model-based estimation? A committee from the American
Statistical Association reviewed the statistical aspects of
EMAP during the same time period as the NRC review.
Although die reviews were supportive of EMAP's use of
survey sampling  and the statistical  underpinnings of the
program,  they also  expressed concerns, as mentioned
above.   These reviews were  valuable inputs to  the
statistical  team  designing EMAP.    They provided

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ammunition to organizations and individuals who were
not in favor of EMAP.

    Understanding the social culture of all organizations
that are involved in or can influence decisions on the
development  and  implementation  of a  monitoring
program is critical. At times, it may take more effort to
manage the social  culture and  its  expectations than to
address the  myriad  of scientific  issues.    This  is
particularly true when the monitoring program is a radical
change from the status quo.

Conclusions

    Some of the issues involved in changing the culture
of monitoring aquatic ecosystems have been given. After
ten  years working within  EPA  as  part  of  the
Environmental  Monitoring and Assessment Program
statistical  design team, I believe  that the monitoring
culture is  changing - but  more  slowly than I expected.
Although   having  a  solid  scientific  foundation  is
important,  understanding  the social culture that affects
the  monitoring program may be more  important.
Significant advances in aquatic monitoring have occurred
as the result of EMAP.  In 1990, no state used survey
designs as an integral part of their monitoring program.
In  1996, two states used survey designs; by 1999 the
number increased to 11 states .  Other states continue to
express interest and most states have been involved in
one or more survey designs developed by EMAP.  By
working with  individual  states on  problems of direct
interest to  them, EMAP has the opportunity to introduce
probability-based  surveys.    The  states  have  the
opportunity to  see how such surveys can. help them
answer some  of their questions. Gradually, support is
building for a cultural change in the use of survey designs
nationally.

    Many  questions remain on  what  a  federal/state
national environmental statistical program might  look
like.  However, it appears certain that progress toward
such a goal is  being made.

Acknowledgments

    The information in this article has been funded in
part by the United States Environmental  Protection
Agency.  It has been subjected to Agency review and
approved for publication.  The conclusions and opinions
are solely those of the author and are not necessarily the
views of the Agency.
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