UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON D.C. 20460
May 1, 1992
OFFICE OF
THE ADMINISTRATOR
SCIENCE ADVISORY BOARD
EPA-SAB-EPEC-LTR-92-008
Honorable William Reilly
Administrator
U.S. Environmental Protection Agency
401 M St., S.W.
Washington, D.C. 20460
RE: SAB Review of the EMAP Program Plan and Concepts for
Integration and Assessment
Dear Mr. Reilly:
The Environmental Monitoring Subcommittee of the Ecological Processes and Effects
Committee of the Science Advisory Board conducted a review on December 4-5, 1991 of the
Environmental Monitoring and Assessment Program's (EMAP) Program Plan. A consultation
was also held at this meeting on the EMAP plans and concepts for assessment of monitoring
data and integration of the ecosystem components. In the charge for this meeting, the SAB
was asked to:
a. Review the revised Program Plan (November, 1991) to assure that the plan is
technically accurate and adequately explains the purpose,, objectives, organization,
capabilities, and limitations of EMAP to an informed Public.
b. Discuss EMAP's concepts and approaches for integration and assessment and
the framework for reporting information.
The purpose of this letter is to advise you of the significant recommendations of the
Subcommittee for further improvements to the Program Plan. Overall, the Subcommittee
believes that the revised Program Plan is very useful and addresses many of the comments of
the earlier SAB review (Evaluation of the EMAP Program Plan EPA-SAB-EPEC-91-011,
July, 1991) However, there are still several areas which need refinements to make the
Program Plan (which has been renamed the "Program Document") more effective in
explaining EMAP. We identified the following topics for further development in the revised
Program Document:
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Continuum Concept
The Draft Assessment Program would benefit from the inclusion of a diagram of the type
on page 8 of the briefing material. This diagram would assist the reader in knowing what is
included in EMAP and what is excluded. The relationship of EMAP to other ecological
programs within the Agency should be included in this and other diagrams (See relationship to
ecorisk).
The figure developed to explain the continuum ranging from data collection through
various forms of assessment should show EMAP's position on that continuum and should be
included in the Program Document, along with sufficient discussion to make clear the
objectives and limitations of each level. The position of other ecological risk assessment
programs in the Agency should also be described.
Conceptual Ecorisk Framework
A relatively high degree of consensus is currently evolving concerning the conceptual
framework for ecological risk assessment (Risk Assessment Forum, Agency Workshops,
NAS/NRC Committee on Risk Assessment Methods). Figure 1 of the Program Document
should incorporate this contemporary thinking and clearly show how EMAP program elements
will affect an ecological risk assessment. A full explanation of how EMAP outputs will
contribute to the accepted steps of hazard identification, exposure assessment, stress-response
and risk characterization will clarify what EMAP is intending to deliver.
Potential Contributions to Ecorisk and Beyond
The program document needs to clarify the relationships between EMAP and other
ecological programs within EPA. We recommend that a figure be developed showing the
relationship of EMAP to the Ecorisk Research Program, the Ecological Risk Assessment
Guidelines and habitat assessment programs of the Agency. The contributions (both real and
potential) that EMAP can make to these programs and the coordination between the programs
should be explained.
A long-term program such as EMAP is much more valuable and viable of it has clear
near-term fallouts (e.g., operating principles, theories or procedures used by EMAP) which
may benefit or contribute to other areas of knowledge and research. These fallouts should be
sought, identified, and publicized by EMAP, and applied within EPA and elsewhere. The
National Aeronautic and Space Agency has been expert in identifying many technological
fallouts from its long-term space program. These contributions convinced the public and
Congress to continue its investment in the effort so that long range goals could be achieved.
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Criteria for selecting indicators
The Document emphasizes the importance of EMAP to the Agency's efforts to ecological
risk assessment. The results of EMAP's monitoring should be valuable inputs to assess
environmental hazards and stresses and provide information on stress/effects relationships.
Therefore, it is essential that individuals with expertise in ecological risk assessment be
involved in the selection of indicators and the sampling design (e.g., temporal and spatial
characteristics, and the required accuracy and precision). Furthermore, the document should
clearly provide for this interaction on a continuing basis as the selection of indicators and
sampling design continues to evolve.
Provide Examples, Definitions, and References
The EMAP Program Document could be improved by including an example of an EMAP
project, a brief glossary, and a list of supporting documents. The current version of the
Program Document outlines approaches and generally describes products and product
applications. A brief description of a project, such as the forest study, would illustrate how a
project is implemented, an outline of the technologies involved, and explain how it can
contribute to ecological risk assessment. A key list of supporting documents should be
available to the public and provide more details on the approaches, methods, and specific
projects of EMAP.
Tiers 3 and 4
The purpose and application of EMAP's Tiers 3 and 4 sampling protocols are inadequately
explained. The Program Document should discuss what these tiers entail, where they fit along
the continuum of data collection and assessment, how they relate to pilot and local-regional
studies (e.g., South Florida initiative), and how these studies would expand and build upon the
base level of EMAP characterization activities.
Data of Known Confidence
The Program Document lists the basic EMAP objective in terms of characterization of the
environment with known confidence, yet the Program Document fails to discuss what that
means, how that would be demonstrated, and what issues are critical to quantify uncertainties.
For example, while the data generated within the internal parameters of the statistical sampling
scheme for a demonstration project were of a known confidence (i.e., lot), the confidence
limits in terms of background variability (i.e., signal vs. noise) were unknown.
Sensitivity Analysis
The EMAP report should include a discussion of sensitivity analysis, i.e., what questions
will EMAP data answer? The use of sensitivity analyses, simulations using hypothetical and
actual data, and power analyses should be discussed in broad, concise terms in the general
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Program Document and in specific details in the companion Program "technical document".
EMAP should structure its sampling programs to include assessments of the natural temporal
and spatial variability of the ecosystem so it can distinguish signals from noise.
Use State-of-the-Art Methods
The Document states little or nothing about the importance of appropriate biological and
chemical analytical methodologies to be employed in the monitoring program and their
precision and specificity. While this may be implicit in the document, it should be explicitly
stated. We recommend that the Program Document give an example of how such methods are
selected and how the quality and compatibility of the data are assured within and between the
resource groups.
Information Management
It is absolutely essential that the system and associated software be fully configured early
in the EMAP program. This will ensure that subsequent data generation and submittals to the
EMAP data base are fully quality-assured and of a form that can be readily incorporated into
the system. We recommend that EMAP consider the use of a relational data base and pilot
options which may be appropriate. The Program Document should describe EMAP's
approach for accessing and handling data from disparate sources to produce the useful data
bases, statistical summaries, and assessments.
Clients for EMAP
There is a fundamental tension for EMAP between the need to provide useful information
to some EPA program office clients and the need to do broad, generic long-term monitoring
that may be able to detect regional changes and trends in ecological resources over time for
the Administrator's needs. EMAP is designed to gather information for the second need,
however, the Program Document implies that EMAP can meet more specific client needs that
can be addressed more efficiently by a focused monitoring effort. The principal client for
EMAP is the Administrator and meeting his needs should be the primary objective. EMAP
serves a vital census that EPA clients, such as the regulatory offices, may not yet recognize as
being important. The Program Document should emphasize the benefits of such information.
User/Client Data Access
The document should contain a description of just how a user or client of the EMAP
system will be able to access data. If the system is to be maximally useful to researchers,
industry and the regulatory community, early definition of the data types and forms available
to the potential user community is essential. The Document should also provide some
tentative or vague schedule for when data may be accessible.
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The Sequencing Problem in EMAP Management
Many of the components of EMAP depend on one another in ways that make the sequence
of their development extremely important. Some activities cannot be pursued until the results
of ether activities are in hand (e.g., preliminary selection of indicators precedes demonstration
r- jjects). Furthermore, there are some activities whose outcomes cannot at present be
predicted, but which will critically affect subsequent strategy and planning decisions. The
Subcommittee recognizes that EMAP design did not evolve following a strict sequence of
activities, and that as experience is gained with demonstration projects and with testing
indicators, the fundamental EMAP sampling strategy and design may require modification.
The Program Document should discuss this problem and reassessment tasks should be included
in the Implementation Plan.
Concepts for Integration and Assessment
The Subcommittee recommended earlier that EMAP prepare a pilot assessment for
SAB review. At the December 4-5 meeting, EPA presented the concepts and prototypes
materials on integration and assessment for discussion with the Subcommittee. The
Subcommittee recommends that EMAP use the oral comments to prepare specific documents
illustrating EMAP approaches for data assessment and integration (including both a regional
& osystem and single resource examples) for SAB review.
Final Thoughts
In summary, we are pleased that the revised EMAP Program Plan has responded to
the Subcommittee's previous recommendations (July, 1991) concerning preparation of an
overview document. We have suggested some refinements and improvements which we hope
the / gency will incorporate into the final Program Plan. A number of fundamental questions
ab- the program still remain to be clarified. We expect that these will be addressed in the
Technical Program Document and Implementation Plan that are now under development. We
look forward to the opportunity to review the Technical Program Document, the
Implementation Plan, and the approaches for data assessment in detail.
Sincerely yours,
Raymond C. Loehr, Chair Kenneth L. Dickson, Chair
Science Advisory Board Ecological Processes and
Effects Committee
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US ENVIRONMENTAL PROTECTION AGENCY
SCIENCE ADVISORY BOARD
ECOLOGICAL MONITORING SUBCOMMITTEE
ROSTER
CHAIR
*Dr. Kenneth L. Dickson, Director, University of North Texas,
Denton, Texas
VICE CHAIR
*Dr. Stanley I. Auerbach, Oak Ridge National Laboratory, Oak
Ridge, Tennessee
MEMBERS
Dr. Donald F. Boesch, University of Maryland, Cambridge,
Maryland
Dr. Mark A. Harwell, University of Miami, Miami, Florida
*Dr. Robert J. Raggett, College of William and Mary, Gloucester
Point, Virginia
Dr. Richard Kimerle, Monsanto Corporation, St. Louis, Missouri
Dr. Betty H. Olson, University of California, Irvine,
California
Dr. Paul Risser, University of New Mexico, Albuquerque, New
Mexico
CONSULTANTS
Dr. Daniel Goodman, Montana State University, Bozeman, Montana
Dr. Allan Hirsch, Midwest Research Institute, Falls Church,
Virginia
Dr. Alan W. Maki, Exxon Company, USA, Houston, Texas
Dr. John Neuhold, Utah State University, Logan, Utah 84322
Dr. Dean B. Premo, White Water Associates, Inc., Amasa,
Michigan
Dr. William H. Smith, Yale University, New Haven, Connecticut
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SCIENCE ADVISORY BOARD STAFF
Dr. Edward S. Bender, Designated Federal Official, US EPA,
Science Advisory Board, 401 M Street, S.W., Washington, D.C.
20460
Mrs. Marcia K. Jolly (K--ccy), Secretary to the Designated
Federal Official
^Members of the Executive Committee
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U.S. ENVIRONMENTAL PROTECTION AGENCY
NOTICE
This repo't has been written as a part of the activities of the Science Advisory Board, a
public advisor: group providing extramural scientific information and advice to the
Administrator and other officials of the Environmental Protection Agency. The Board is
structured to provide a balanced expert assessment of scientific matters related to problems
facing the Agency. This report has not been reviewed for approval by the Agency; and hence,
the contents of this report do not necessarily represent the views and policies of the
Environmental Protection Agency or other agencies in Federal government. Mention of trade
names or commercial products does not constitute a recommendation for use.
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