United Slates           Office of Marine          September 1988
                  Environmental Protection     and Estuarine Protection
                  Agency              Washington DC 20460

                  Office of Water/National Estuary Program	
<>EPA          Estuary Program          draft
                  Primer

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Estuary Program Primer
   National Estuary Program
Office of Marine and Estuarine Protection
 U.S. Environmental Protection Agency
        Draft: for Review Only
           October 1987

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ACKNOWLEDGEMENTS



     (copy to come)

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                   CONTENTS

Foreword (copy to come)

I  The National Estuary Program: An Overview	1
  Unique Resources	1
  What Is the National Estuary Program?	1
  Historical Perspective  	2
      Great Lakes Program  	2
      Chesapeake Bay Program  	3
  Roots of the National Estuary Program	4
  Water Quality Act of 1987  	•	5
  The National Estuary Program's Approach	6
      Management Conference	6
      Characterization and Problem Definition	7
      Comprehensive Conservation and Management
      Plan  	7
  Estuary Program Primer	7

II The Planning Initiative: Building a Management
  Framework  	11
  Collaboration and Flexibility: Essential Ingredients ....  11
      Building a Constituency	11
      A Local-State-Federal Partnership   	12
  Management Conference:  The Umbrella for Action  ...  12
      Management Conference Process	12
      Starting in the Right Direction	13
      Who Are the Members  of the Management
      Conference?   	  13
  Policy Committee   	14
      What Does the Policy Committee Do?   	17
      Who Are the Members  of the Policy Committee?  . .  17
  Management Committee	18
      What Does the Management Committee Do?  ....  18
      Who Are the Members  of the Management
      Committee? 	19
  Scientific and Technical Advisory Committe  	19
      What Does the Scientific and Technical Advisory
      Committee Do?   	20
      Who Are the Members  of the Scientific and Technical
      Advisory Committee?	20
  Citizens Advisory Committee  	21
      What Does the Citizens Advisory Committee Do?  . .  21
      Who Are the Members  of the Citizens Advisory
      Committee?   	22
  Staff Support for the Management Conference	22

III Characterization and Problem Definition  	25
   Setting the Course   	25
   Scientific Characterization	26
   Characterization Steps	27
      Identification and Ranking of Priority
      Problems for Study  	27

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     Collection of Priority Data Sets  	   29
     Identification of Data Management Support	30
     Screening Priority Data Sets	31
     Estuary Segmentation	31
     Data Analysis	32
     Consideration of Incomplete  Data   	35
     Reporting of Results	37
    Evaluation of Institutional and Management Programs   . 38
    Characterization Report	39


IV The Comprehensive Conservation and Management
    Plan	   41
    A Blueprint for Action	41
    Developing a Comprehensive Conservation and
    Management  Plan	41
    Components of a Comprehensive Conservation and
     Management Plan	42
    A Summary of the Characterization Findings	   43
    Priority Problems Addressed in the CCMP	44
    Environmental Quality Goals and Objectives for
    the Estuary	45
     Setting Goals	45
     Setting Objectives	45
    Action Plans for Controlling Pollution and Managing
    Resources	      	   46
     Water and Sediment Quality	48
     Living Resources Management	49
     Land Use and Water Resources Management	54
    Supporting Components	    55
     A Plan for Public Information and Involvement  ....   56
     Provisions for Program Integration and
     Coordination	57
     Provisions for Periodic Review, Evaluation, and
     Redirection	   58
      Provisions for Implementation	   59
APPENDIXES

A.  Federal Financial Assistance Under the National Estuary
    Program

B.  Building an Effective Public Participation Program

C.  Using Finfish As Indicators of Toxic Contamination

D.  Summary of the Guidance Manual for Health Risk
    Assessment for Consumption of Chemically
    Contaminated Fish and Shellfish

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FOREWORD





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                               GLOSSARY
                                (copy to come)
Anadromous fish
Benthic invertebrates
Basinwide
Carcinogenic potency factor
Data sets
Designated uses
Dissolved oxygen
Estuarine zone
Estuary
Estuary characterization
Estuary segmentation
Eutrophication
Gradients
Marine biota
National Pollutant Discharge
Elimination System (NPDES)
Nonpoint source
Nutrients
Organic carbon
Pathogenic organisms
PH
Pharmacokinetic
Phytoplankton
Plankton
Point source
Pollutant loading
Pristine area
Risk assessment
Risk management

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Tidal flushing
Tidal head
Tissue residue
Turbidity
Wasteload allocation
Water quality management plans (Section 208)
Watershed
Watershed geomorphology
Zooplankton

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                                                                      Chapter I
                     The National  Estuary Program:
                                                          An Overview
                                                          Unique Resources
Estuaries are unique waterways where fresh water drained from
the land mixes with salt water from the ocean This blend of salt
and fresh water makes estuaries biologically productive, sustain-
ing certain finfish, shellfish,  marshes, underwater grasses, and
microscopic marine life Because of their economic, aesthetic, and
recreational value,  estuaries are increasingly  attracting both
people and commerce to their shores Aquatic life is affected by
these growing populations, which need and use water for services
as well as for commercial and industrial activity

In establishing the  National Estuary Program under the Water
Quality Act of 1987, Congress recognized the special need to
protect an important but endangered resource our nation's estu-
aries
       According to the 1972 Federal Water Pollution Con-
       trol Act, "the term 'estuary' means all or part of the
       mouth of a  river or stream or other body of water
       having unimpaired natural connection with the open
       sea  and within which  sea  water  is  measurably
       diluted  with  fresh water derived from land drain-
       age " The 1987 amendments, known as the Water
       Quality Act of 1987, expand the definition to include
       "associated aquatic ecosystems and those portions
       of tributaries draining into the estuary up to the his-
       toric height  of migration of anadromous fish or the
       historic head of tidal influence, whichever is higher"
The National Estuary Program is managed by the Environmental
Protection Agency (EPA) to identify nationally significant estuaries
threatened by pollution, development, or overuse, and to promote
the preparation of comprehensive management plans to ensure
their ecological integnty  The program's goals  are protection
                                                          What Is the National
                                                          Estuary Program?

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Historical  Perspective
       Great Lakes Program
                                   and improvement of water quality,  and  enhancement of living
                                   resources.

                                   To achieve these goals, the National Estuary Program conducts
                                   activities to help:

                                      . Establish working partnerships among federal, state, and
                                        local governments;
                                      . Transfer scientific and management experience and
                                        expertise to program participants;

                                      . Increase public awareness of pollution problems and
                                        ensure public participation in consensus building;

                                      . Promote basinwide planning to control pollution and
                                        manage living resources; and
                                      . Oversee development and implementation of pollution
                                        abatement and control programs.
                                    The National Estuary Program has roots in earlier efforts and legis-
                                    lation. The experiences of the Great Lakes and the Chesapeake
                                    Bay provide useful models and lessons for the new program.

                                       .  The first is the phased program approach used to identify
                                         and define priority problems, establish their probable
                                         causes, and devise alternative strategies to address them.

                                       .  The second is the collaborative problem-solving process
                                         that involves all concerned parties in each phase of the
                                         program and secures commitments to carry out
                                         recommended actions.
                                    Launched in 1970, the Great Lakes Program is the oldest estuary
                                    program in  this country. A cooperative effort between the United
                                    States and  Canada, the program fulfills the Great  Lakes Water
                                    Quality Agreements of 1972 and  1978 between the U.S.  and
                                    Canadian governments. Waters of the Great Lakes were burdened
                                    with too many nutrients. The resulting eutrophication problems
                                    were depleting the supply of oxygen dissolved in the water, thus
                                    killing fish.  Excessive phosphorus  discharges were  cited as the
                                    probable cause.

                                    The program initially tackled control of pollution from individual,
                                    identifiable  sources Major municipal treatment plants were re-
                                    quired  to  reduce  phosphorus  in effluents,  and  phosphate
                                    detergent was banned in many of the Great Lakes states. These
                                    efforts  to  reduce  point-source  pollution,  which  successfully
                                    reduced nutrients, resulted in elevated oxygen levels and restora-
                                    tion of some fish in Lake Erie and elsewhere.

                                    The Great  Lakes Program  then turned to nonpoint sources of
                                    pollution. The principal nonpoint source of  excess nutrients was
                                    the runoff of surface water from agricultural  land. This water car-
                                    ries topsoil laden  with nutrients  (including  fertilizers) to  the
                                    estuary. To demonstrate the value of nonpoint source controls,
                                    the Great Lakes Program Office, working with the Department of

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Agriculture's Soil Conservation Service, funded projects with indi-
vidual farmers. These projects were aimed at controlling nonpoint
source pollution in several states The program illustrated how
voluntary best management practices could reduce phosphorus
loadings from agricultural sources, especially into Lake Erie and
Lake Ontario  Today the states have their own phosphorus control
programs as part of the implementation agreement with Canada.

After adopting measures to control point and nonpoint sources of
nutrients, the Great Lakes Program focused on methods to abate
pollution caused by nonpoint sources of toxics Toxic pollution is
the result of  activities that have occurred in the watershed for
many years The Great Lakes Program is also studying the effects
of airborne toxics

One lesson from the Great Lakes Program is that all the pollution
controls  evolved  from a  phased process-  identifying pollution
problems, evaluating alternative solutions, and  making  recom-
mendations to state and local governments

A  second lesson is  recognition of the need  for  continuous
monitoring of water quality and living resources. Without monitor-
ing, there is  no way to know whether the actions taken have
worked The  Great Lakes  Program is carrying out a monitoring
plan that surveys the lakes to determine the levels of and trends in
concentrations  of nutrients, metals,  and toxics  The results will
enable the United States and Canada to assess compliance with
the objectives of the agreement, evaluate the effects of the control
program, and identify emerging problems
The Chesapeake  Bay Program, which was mandated by Con-
gress, began in 1977 as a federal-state partnership. From 1978 to
1982,  scientists examined the bay They found that phosphorus
and nitrogen loads from both point and nonpoint sources were the
chief causes of the bay's declining water quality and resources. As
a result, specific recommendations were made in 1983 to reduce
sources of the nutrients and to clean up the bay.

The findings and recommendations of the study spurred the states
to action In 1983, the governors of Maryland, Virginia, and Penn-
sylvania, and the  mayor of the District of Columbia, signed the
Chesapeake Bay Agreement with EPA's Administrator. The agree-
ment commits the states and the District to prepare plans that will
improve and protect the bay's water quality and living resources
The following actions are being implemented successfully

  •  Institution of land-use controls at or near the bay shoreline;
  •  Development of nonpoint source control programs for
    agricultural and urban sources,

  •  Acceleration of tighter controls of point sources, particularly
    municipal treatment plants; and

  •  Strengthening of wetlands protection laws and programs.
                                                                 Chesapeake Bay Program

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Roots of the National
      Estuary Program
                                  In an ongoing effort to carry out these plans, the state legislatures
                                  and the District of Columbia have appropriated money to effect
                                  the program's recommendations. The federal government con-
                                  tinues  to  provide  resources  to assist  in  bay cleanup. The
                                  Chesapeake Bay and Great Lakes programs  are both continued
                                  under the 1987 Water Quality Act
                                  The lessons learned and the precedents set by the Chesapeake
                                  and Great Lakes programs, along with federal legislation, helped
                                  lay the foundation for the National Estuary Program. This program
                                  employs  collaborative problem-solving approaches to  balance
                                  conflicting  uses while  restoring or  maintaining the estuary's
                                  environmental quality. Further,  the program follows  the  basic
                                  problem identification, characterization, and phased management
                                  process learned from the  preceding  efforts. The steps in this
                                  process are to:

                                     .  Define the environmental problems and explore their
                                       probable causes;

                                     •  Assess existing laws, regulations, and control programs,
                                       revising or expanding them if necessary;

                                     .  Review and revise current designated uses of portions  of
                                       the estuary and freshwater tributaries;

                                     .  Identify and recommend alternative management
                                       strategies to improve the estuary; and
                                     •  Develop specific action plans, with resource commitments
                                       and compliance schedules, for implementing the selected
                                       strategies.
                                  Through the experiences of  the Great Lakes and and Chesapeake
                                  Bay programs, EPA and program participants also learned how to
                                  get results  with  less  money. The National  Estuary Program
                                  achieves this by focusing on the most significant problems,  using
                                  existing data,  emphasizing applied  research, funding specifically
                                  targeted basic research, and employing  demonstrated manage-
                                  ment strategies. These techniques save both time and money, but
                                  more importantly, lead to earlier corrective actions.

                                  In 1985, the Congress directed EPA to  conduct programs in four
                                  estuaries: Narragansett Bay in Rhode Island,  Buzzards Bay in
                                  Massachusetts, Long Island Sound in New York and Connecticut,
                                  and Puget Sound in Washington. In 1986, EPA added San  Fran-
                                  cisco Bay in California and  Albemarle/  Pamlico Sounds in  North
                                  Carolina to the program.

                                  The two estuaries were added because EPA believed it was appro-
                                  priate to extend the program to new coastal areas. The  Agency
                                  also  wanted  to expand the types of pollution  problems  being
                                  addressed, while making certain they were issues of national con-
                                  cern. EPA was further  persuaded  by  the obvious  commitment
                                  state and local governments and the public in these estuaries had
                                  already made to pollution abatement.  However, it was clear they

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could still benefit  from the expertise available through EPA's
national program

The types of environmental problems the national program ad-
dressed were, and remain,  complex They include loss of habitat
and living resources, contamination of sediments by toxics, eleva-
tion of nutrient levels, contamination by bacteria, and depletion of
oxygen These problems can affect human health through contact
with  the  water and by mgestion of contaminated shellfish and
fmfish More frequently,  pollution problems limit desirable uses of
the estuary  like  recreational  and commercial  linfishing  and
shellfishmg. and  may  even close beaches to swimming Other
important uses,  such as shipping, municipal and industrial water
use,  and  disposal, may  not  be  affected  by  environmental
problems Nevertheless, the program assumes that these conflict-
ing use demands can be met through collaborative planning

Through 1986, program activities were supported by broad legis-
lative  authorities   and   funding  appropriations   Despite  the
complexity and  pressing nature of the problems, the Congress
had yet to enact legislation aimed specifically at these fragile
bodies of water  This situation was about to change
Passage of the Water Quality Act of 1987 signaled recognition by
Congress  that the health of the nation's estuaries had to be
protected  The new law amends and extends the Federal Water
Pollution Control Act of 1972 and its 1977 amendments, known as
the Clean  Water Act  The Water Quality Act formally establishes
the National Estuary Program Section 317 declares that the in-
crease in coastal population, demands for development, and other
direct and  indirect uses of  the estuaries threaten these unique
bodies of water  The law Further states that it is in the national inter-
est to maintain  the ecological integrity of the nation's estuaries
through long-term planning and management
         An estuary program is woven together by
            two themes: progressive phases for
            identifying and solving problems and
               collaborative decision making.
Section 320  authorizes  the  EPA Administrator  to  convene
Management  Conferences to develop comprehensive plans for
estuaries of national significance The conferees are charged with
balancing  the conflicting uses in the estuary while restoring or
maintaining its natural character

The law acknowledges the importance of collaboration by requir-
ing Management Conferences; it also requires implementation by
the conferees Furthermore, it reflects the phased process used in
the Great  Lakes and Chesapeake Bay programs  Through this
process, each estuary program examines changes in water quality
                                                                Water Quality Act
                                                                of 1987

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The  National Estuary
Program's Approach
Management Conference
                                     and natural  resources, evaluates  point and  nonpoint  pollutant
                                     loading, and determines their relationship to pollution problems.
                                     The Conference then devises a  management  plan to address
                                     these problems. The law supports the notion that, through colla-
                                     borative planning, disputes about uses of water can be resolved It
                                     also endorses the value of education and research as  essential
                                     components of longer term efforts to restore and maintain estu-
                                     aries.
                                        Section 320(b) of the Water Quality Act of 1987 states the purposes of
                                        Management Conferences as follows:
                                             (b) PURPOSES OF  CONFERENCE  The purposes of any
                                           management conference convened with  respect to an estuary
                                           under this subsection shall be to -
                                             (1) assess trends in water quality, natural resources, and
                                           uses of the estuary;
                                             (2) colled, characterize, and assess data on toxics, nutrients,
                                           and natural resources within the estuarme zone to identify the
                                           causes of environmental problems,
                                             (3) develop the relationship between the inplace loads and
                                           point and nonpoint loadings of pollutants to the estuarme zone
                                           and the potential  uses of the zone, water quality, and natural
                                           resources,
                                             (4) develop a comprehensive conservation and management
                                           plan  that  recommends priority  corrective actions and  com-
                                           pliance schedules addressing point and nonpoint sources of
                                           pollution  to restore and maintain the chemical, physical, and
                                           biological  integrity of the  estuary,  including  restoration and
                                           maintenance of water quality, a balanced indigenous population
                                           of shellfish, fish and wildlife, and recreational activities in the es-
                                           tuary, and assure that the designated uses of the estuary are
                                           protected;
                                             (5) develop plans for the coordinated implementation of the
                                           plan  by the States as well as Federal and local agencies par-
                                           ticipating in the conference,
                                             (6) monitor the effectiveness of actions taken pursuant to the
                                           plan; and
                                             (7) review all Federal  financial assistance program and
                                           Federal development project in accordance with  the require-
                                           ments of Executive Order 12372, as in effect on September 17,
                                           1983, to determine whether such assistance program or project
                                           would be consisted  with and further the purposes and objec-
                                           tives  of the plan prepared under this section
                                     The  National  Estuary Program's  approach  is  to  convene  a
                                     Management Conference, characterize  the estuary,  define the
                                     estuary's problems, and develop the Comprehensive Conserva-
                                     tion and Management Plan (CCMP).
                                     After  the EPA Administrator selects an estuary for the National
                                     Estuary Program, the  Administrator convenes  a Management
                                     Conference to  oversee  activities.  The Conference consists of
                                     representatives of EPA, state  and foreign governments,  appro-
                                     priate interstate or regional agencies and other appropriate federal
                                     agencies, local governments, affected industries,  public and
                                     private educational institutions, and the general public.

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The Conference defines the problems of the estuary and, from a
broad array of concerns, selects specific areas to investigate Nar-
rowing the  field,  establishing  priorities, and  selecting which
problems to tackle is a challenge To meet that challenge, the
Management Conference addresses the following questions.

  •  Is the environmental problem systemwide and pervasive, or
    is it local, affecting small areas only''
  •  If the problem is local, is it nevertheless significant enough to
    adversely affect the entire estuary or its resources7
  •  Does the problem reduce the estuary's ability to support
    beneficial uses7

  •  What information can be used to identify the causes of the
    problem7

  •  What actions can be taken to abate the problem or its
    causes7
The Conference then performs an objective, technical assessment
of the state of the estuary  It also evaluates the management
programs in  place to protect the  estuary  This phase, called
characterization, is the basis for identifying and selecting .the
problems to be addressed in the Comprehensive Conservation
and Management Plan  A blueprint for achieving environmental
protection  in  the estuary, the CCMP requires a commitment to
action by the conferees
A CCMP summarizes the estuary's problems and indicates which
ones  will  be addressed  Through a collaborative process,  the
Management Conference establishes program goals and objec-
tives, determining desirable and allowable uses for the estuary and
its various segments Specific pollution control and  resource
management strategies, designed to meet each objective, are the
core of the  CCMP After evaluating the strategies carefully,  the
conferees select  those  producing  the greatest environmental
benefit -  at  the least cost and in the most timely manner - for
action Strong public support and subsequent political  commit-
ments are required to carry out the actions agreed to in the CCMP.
Each estuary  program must  establish its own objectives and
operating  methods, which will depend on  the  character and
problems indigenous to its body of water The interests and values
of its public are also a paramount  concern With flexibility  to
respond to the uniqueness of each estuary, all programs will entail
the same four phases  These phases will be highlighted here and
                                                                Characterization and
                                                                Problem Definition
                                                                Comprehensive
                                                                Conservation and
                                                                Management Plan
                                                                Estuary Program
                                                                Primer

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discussed thoroughly in the following chapters.  Figure 1.1  gives
an overview of the process.


                    National Estuary Program
              Section 320 of the Water Quality Act
         Governor's
         nomination
            EPA
        Administrator
          convenes
        Management
         Conference
            I
    Estuary
    Characterization
    • Assess trends,
      collect and analyze
      data, and evaluate
      pollutant loads
    • Review, evaluate,
      and redirect existing
      programs	
                     6 Years
     Management
     Conference develops,
     and Administrator
     approves,
     Comprehensive
     Conservation and
     Management Plan
     (CCMP)
            I
       Implementation
           plans
-i
 Monitoring to assess
environmental results;
  simultaneous with
   implementation
                          -6-16 Years-
 Figure 1.1
Phase 1, the Planning Initiative, consists of building a manage-
ment organization  for  identifying and solving problems.  This
includes setting up the Management Conference and committee
structure  (Chapter II).  During Phase 2,  Characterization  and
Problem Definition, the state of the estuary and  its problems are
defined (Chapter III). The chief task of Phase 3 is to create a Com-
prehensive Conservation and Management Plan. The CCMP is
designed, developed, and adopted by the  Management Con-
ference (Chapter IV).

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Implementation of the CCMP and reassessment of needs occur
during Phase 4. Specific guidance for this phase will be«provided
in 1988. Implementation will be the responsibility of the Manage-
ment Conference using the resources provided under the Water
Quality Act of 1987 and other federal, state, and local auspices.
                  Management Process
   Phase 1    Planning Initiative: Building a Management
             Framework
   Phase 2    Characterization and Problem Definition
   Phase 3    Creation of a Comprehensive Conservation
             and Management Plan
   Phase 4    Implementation of the Comprehensive
             Conservation and Management Plan

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                                                                Chapter II
              The  Planning  Initiative: Building a
                                Management  Framework
The management framework is essentially a vehicle for decision
making. Conflicting needs and uses must be balanced without
compromising the environmental goal of maintenance and restor-
ation of the estuary. Not surprisingly, these decisions are often
fraught with tensions. Therefore, each Management Conference
must serve as a forum for open discussion, cooperation, and com-
promise among disparate interests, resulting in consensus. Such
a forum is the instrument for collaborative decision making that
leads to acceptance and support for implementation actions.
When creating its committee structure, the Conference targets
four constituencies: elected and appointed policy-making officials
from all  governmental levels; environmental  managers from
federal, state, and local agencies; local scientific and academic
communities; and private citizens and representatives from public
and user interest  groups  — businesses, industries, and com-
munity and environmental organizations. These constituents are
all key members of the Conference.
     A Management Conference is a forum for open
     discussion, cooperation, and compromise that
                 results in consensus.
Because each estuary is a unique body of water, its problems,
citizens' concerns and preferences, state and local governments,
and institutions are also unique. So flexibility Is the key to organiz-
ing and managing an effective estuary program. Local needs and
                                                      Collaboration and
                                                      Flexibility: Essential
                                                      Ingredients
                                                      Building a Constituency
                                                                             11

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      A Local-State-Federal
                 Partnership
            Management
       Conference: The
    Umbrella for Action
  Management Conference
                    Process
                                   values are among the important forces driving the creation of a
                                   specific management organization - a framework that will deter-
                                   mine program goals and objectives and how to achieve them
                                   As a local-state-federal partnership, the framework must also take
                                   into account differences in how state and local governments are
                                   organized. The division of responsibilities among resource, water,
                                   and commerce agencies,  and the degree  of centralization in
                                   environmental planning,  are equally important considerations.
                                   Therefore, program planning and management for each estuary
                                   will probably involve a somewhat different mix of public agencies
                                   and different levels of representation. Flexibility ensures a dynamic
                                   program that allows both structure and strategy to be modified in
                                   response to successes, failures, political realities, and unforeseen
                                   problems.

                                   Many of the strategies considered in the estuary program will re-
                                   quire new laws, regulations, and policies. It may be necessary to
                                   create institutions or to modify the mission of existing ones. Each
                                   state and local government has its own rulemaking process. It is,
                                   therefore,  essential to understand how the systems work in the
                                   jurisdictions participating in an estuary program.

                                   The recommendations in this chapter stem from EPA's experience
                                   with other estuary programs and the suggestions of  their parti-
                                   cipants. They are offered only as guidelines, since the character of
                                   each program will be different.
                                   As Chapter  I  described, the Water Quality Act established the
                                   National Estuary Program to promote comprehensive planning for
                                   estuaries of "national significance" that are threatened by pollu-
                                   tion,  development,  or  overuse.  The EPA Administrator,  who
                                   decides which estuaries will be part of the program in response to
                                   nominations submitted  by  state governors, assumes significant
                                   responsibility. The Administrator may convene Management Con-
                                   ferences for estuaries with boundaries in more than one state. The
                                   Act relies on  state implementation of its programs.  Accordingly,
                                   the states are responsible for most estuary program activities.
                                   The Management Conference, authorized by Section 320 of the
                                   Act, is the organizational  umbrella under which each estuary
                                   program is conducted. Initially convened for up to five years, the
                                   Conference may be extended or reconvened to oversee imple-
                                   mentation and to redirect or adopt new strategies.
12

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The Conference's first  major task is to build the management
framework for identifying and solving problems in the estuary.
Remembering the two themes  driving an estuary program  -
progressive  phases for identifying and solving  problems and
collaborative decision making - the Conference initiators begin
to identify or build a constituency for the estuary.
A  kickoff meeting  is  a good way to start because it serves a
number of purposes As a media event, it can make the public
aware that all is not well in the estuary. And as an educational plat-
form, it is a forum  for identifying estuary problems and public
concerns The kickoff meeting is also an opportunity to involve all
interested people and groups concerned  about and affected  by
the estuary program Furthermore, it is a chance to include  in-
fluential officials in the earliest deliberations.

As an outgrowth of  the kickoff meeting, a committee structure is
set up and  assigned  responsibilities by the Management Con-
ference Each  estuary program will design a committee structure
to meet its particular needs The Conference must strive to under-
stand the community of the estuary, how decisions  are reached,
what perceptions are prevalent, and who or what institutions are
influential The size of the community will also make a difference.
For  instance,  a comparatively small  area like Buzzards  Bay,
located within  a single state, requires a simpler committee struc-
ture than the much  larger interstate estuary. Long Island Sound.
Generally, the  structure consists of a policy-making committee, a
management  committee,  and  work groups or subcommittees,
including a  scientific and technical  advisory committee (STAC)
and a citizens advisory committee (CAC)

The organizational  structures of several  existing programs are
depicted in Figures 2.1 through 2.6.
The Conference members include the EPA Administrator (or his or
her designee), representatives of state, local, and foreign govern-
ments; and other appropriate interstate or regional agencies and
entities. Affected industries, public and private educational institu-
tions, and the general public are also represented  Collectively, all
participants constitute the Management Conference.

EPA may act as  the lead  agency or serve as a cooperating or
sponsoring agency for each program. EPA's role is primarily to
facilitate and provide scientific and management expertise. The
Conference may  involve  other federal agencies, such as the
National Oceanic and  Atmospheric Administration  (NOAA), the
Corps of Engineers, the Soil Conservation Service, and the Fish
and Wildlife Service.
                                                                 Starting in the Right
                                                                 Direction
                                                                 Who Are the Members of
                                                                 the Management
                                                                 Conference?
                                                                                             13

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                                                      Management Conference
                                                         EPA Administrator
                                                           State Governor
                                                               Policy
                                                             Committee
                                                         Appointed by EPA
                                                       Administrator and State
                                                              Governor
                                            Management
                                             Committee
                                        Environmental managers
                                          from participating
                                          agencies—federal,
                                          state, local; other
                                            representatives
       Citizens Advisory
       Committee (CAC)
    Scientific and Technical
     Advisory Committee
           (STAC)
                                       Represented by policy and management committees, by CAC
                                       and STAC, but also participating as part of the Management
                                       Conference:
                                         Elected officials
                                         Civic organizations
                                         Educators
                                         Businesses
                                         Boaters
Environmental groups
Scientists
Industries
Recreational fishing groups
General public
                                     Figure 2.1
      Policy Committee
                                    Generally, estuary programs have identified a need for a high-level
                                    committee composed of federal, state, and local governmental
                                    decision makers. The policy committee (usually called  a policy,
                                    lead, or sponsoring agencies committee) directs all Management
                                    Conference activities. Committee members are key officials,  or
                                    their designees,  who are in a position to  ensure the resources
                                    and funding  needed to support the program   They usually are
                                    appointed by the EPA Administrator or a state governor. Highly
                                    sensitive to both the special interests  and  needs of constituent
                                    groups, they are also well aware  of  the  realities of time and
                                    resource constraints that confront environmental  management
                                    agencies. Therefore, they routinely make decisions after weighing
                                    costs, benefits, and public opinion Within the Management Con-
                                    ference, their positions require them to make such decisions on
                                    behalf of their respective governments or agencies.
14

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                Management Conference
                    Policy Committee
             Two EPA Regional Administrators
                 Two states' environmental
                      commissioners
                           1
                 Management Committee
               Environmental managers from
               participating federal, state, and
                    interstate agencies
                  Chairs of TAC and CAC
     Technical Advisory
         Committee
           (TAC)
 Scientists from federal, state,
and local agencies; universities
      Citizens Advisory
         Committee
           (CAC)
   Representatives from all
  interested groups, including
user and environmental groups
Figure 2.2
                 Management Conference
                     EPA Administrator
                      State Governor
  Policy Committee
   Management
    Committee
          Local Governments
              Committee
    Citizens Advisory
    Committee (CAC)
           Scientific and
        Technical Advisory
        Committee (STAC)
 Figure 2.3
                                                                                           15

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Management Conference


Sponsoring Agencies
Committee
Appointees of EPA Regional
Administrator. State Governor (s),
and Project Office
1

Management
Committee
Figure 2.4





Technical Advisory
Committee
(TAC)

                                                   Management Conference
                                                        Policy Committee
                                                         EPA Region(s)
                                                            State(s)
                                                     Management Committee

                                                    Federal, state, local agency
                                                    representatives; CAC and
                                                    TAC chairs
                                       Technical Advisory
                                          Committee
                                            (TAC)
                                     Federal, state, and local
                                      agencies; community
                                         representatives
 Citizens Advisory
Steering Committee
 Citizens Advisory
   Committee
     (CAC)
                                   Figure 2.5
16

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                Management Conference
                    Sponsoring Agency
                        Committee
                       Management
                       Conference
       Technical
  Advisory Committee
        (TAC)
      Public
Advisory Committee
      (PAC)
Figure 2.6
The policy committee sets program  goals  and objectives and
establishes priorities and direction for the estuary  program Its
members  decide  on  recommendations from  all  committees
Although the policy committee guides, reviews, and evaluates the
program, it leaves the operational duties to other working commit-
tees
The EPA Regional Administrator and the governors of involved
states or their designees are members of the key policy commit-
tee Other political appointees, such as state secretaries of natural
resources or environmental protection, may sit on the committee.
A local mayor or other elected officials may serve; so may senior
regional EPA managers (the Deputy Regional Administrator or the
Water  Management  Division Director)  One or more  senior
regional agency officials may be appointed by the governor of
each participating state Additional state and local representatives
may also be members These include appointees from the water
department or water quality board, the public health department,
or the department of natural resources In some programs, STAC
and CAC chairpersons also sit on the policy committee
                                                               What Does the Policy
                                                               Committee Do?
                                                               Who Are the Members of
                                                               the Policy Committee?
                                                                                          17

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            Management
               Committee
              What Does the
   Management Committee
                        Do?
                                   An effective management committee communicates and colla-
                                   borates among its members to build consensus for recommended
                                   actions. Members represent water quality, resource management,
                                   and other important environmental perspectives. They understand
                                   the estuary, what needs fixing, and what mechanisms are available
                                   or needed to fix it. The management committee members serve as
                                   the focal point for consensus building among Conference partici-
                                   pants and all  other committees. Their recommendations reflect
                                   this process.

                                   Weighing differences and negotiating compromises can be diffi-
                                   cult. Assume,  for example, an estuary program has a $100,000
                                   budget. The STAC believes this budget must support research to
                                   find out what is causing a decline in oyster reproduction. The user
                                   groups within the CAC want to establish oyster farming to offset
                                   the decline. The state environmental agency wants to manage
                                   septic systems in certain shore communities, because bacterial
                                   contamination is closing oyster beds. Opening such beds can off-
                                   set the decline in production.

                                   In these negotiations, members recognize that scientific studies to
                                   determine the cause of the decline may take several years. Never-
                                   theless, the management committee may negotiate an agreement
                                   that allows for all three approaches in  a phased program. The
                                   committee also understands that oyster farming may not succeed
                                   if the same problem affects new oysters. The committee may seek
                                   professional negotiators to facilitate consensus. In fact, failure to
                                   settle disputes amicably and early can lead to serious polarization,
                                   thus impeding later progress.

                                   When setting up this committee, several pitfalls should be avoided.
                                   These include spending too much on a scientific study that will not
                                   yield results for years; committing resources to  address a symp-
                                   tom, but neglecting its cause; and failing to keep lawmakers and
                                   other influential citizen leaders informed and involved.
                                   It is in the management committee that the tough day-to-day work
                                   gets done  Advised by staff, work groups, and other committees,
                                   the management committee defines and ranks the problems of the
                                   estuary,  produces characterization reports,  develops manage-
                                   ment  strategies, and  designs  the CCMP. All  management
                                   committee activities, including implementation, occur under the
                                   general guidance and direction of the policy committee.

                                   In conjunction with the STAC, CAC, and work groups or subcom-
                                   mittees,  the management  committee develops the annual and
                                   five-year work plans and budgets required by EPA, and approves
                                   all  resource and funding allocations. (Appendix A describes the
                                   federal financial assistance process.) Planning to meet congres-
                                   sional deadlines, develop budgets and schedules, and meet work
18

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plan commitments is essential. The consensus-building process
must account for this need.

The committee also oversees and supports the activities of the
STAC. CAC, and the work groups or subcommittees. It is respon-
sible for informing the public and providing for public involvement
during  each  program phase  To ensure this, the management
committee, working with the CAC, develops and funds a public
participation  program  It recommends key members for the STAC
and CAC, and establishes clear roles and responsibilities for them
When the management committee fails to give both the STAC and
the CAC a job to do, these key elements of the program founder.
The management committee may include the EPA regional Water
Management Division Director and representatives of state and
local agencies from each participating state. Mid-level agency
managers and technical  staff usually serve on  this  committee
Naturally, the number of representatives depends on the number
of agencies involved Nevertheless, the areas that should be repre-
sented include natural resources, pollution control, and planning
Representatives of the STAC and the CAC are also management
committee members Other members may include representatives
of local  academic and  scientific  communities, environmental
groups, industry, and user organizations like receational and com-
mercial fishery associations
Each estuary program should determine the specific role and
responsibilities of the scientific and technical advisory committee.
It is especially important for the management committee to deter-
mine how the STAC is to function It is equally important for the
STAC to understand that the estuary program is fundamentally a
planning  and management  program, rather than a  research
program

At the same time, program managers must recognize the impor-
tance of basing the management strategies on sound scientific
information The STAC provides the science in estuary programs,
identifying and defining the estuary's environmental problems The
STAC also  recommends scientific studies, investigations, samp-
ling, and monitoring programs that are necessary to determine the
causes of environmental problems
                                                              Who Are the Members of
                                                              the Management
                                                              Committee?
                                                              Scientific and
                                                              Technical Advisory
                                                              Committee
                                                                                         19

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   What Does the Scientific
    and Technical Advisory
            Committee Do?
   Who Are the Members of
           the Scientific and
         Technical Advisory
                Committee?
                                   The STAC reports to the management committee, and  its chair-
                                   person may sit on that committee or on the policy committee. The
                                   STAC provides advice and guidance  related to research, data
                                   management, modeling,  and sampling and monitoring efforts,
                                   which affect the  scientific adequacy  of the  estuary  program
                                   activities.  Depending on the problem, STAC members suggest
                                   the specific scientific activities necessary to meet program objec-
                                   tives established by the Management Conference. The STAC also
                                   conducts peer review of studies, reports on the status and trends
                                   in the estuary, and alerts the management committee to emerging
                                   environmental problems. In addition, it oversees the assembly and
                                   analysis of historical data bases for characterizing the estuary. To
                                   ensure scientific  rigor and quality, the STAC also reviews the
                                   development  of  any  requests  for  proposals  and the actual
                                   proposals submitted.

                                   In carrying out its responsibilities,  the STAC  may create  work
                                   groups and subcommittees. It may also advise the management
                                   committee on the selection of work group members. The STAC
                                   may help provide initial direction for each work group or subcom-
                                   mittee. In addition, it may determine objectives and likely sources
                                   of scientific, technical, and logistical support required to perform
                                   assigned tasks.
                                   Members  are nominated  by the management committee and
                                   appointed by the policy committee. They are selected with advice
                                   from local, state, and  federal agencies; regional scientists; and
                                   public or private institutions conducting scientific studies in the
                                   water basin.

                                   STAC members, who should represent a balance of scientific dis-
                                   ciplines, may be noted local experts or outside scientists. An EPA
                                   regional representative from the Office of Research and Develop-
                                   ment should be included as well. Typically, members should have
                                   expertise in the following areas:

                                      • Sources of nutrients/toxics;
                                      • Transport and fate, including modeling;
                                      • Ecological and human health effects; and

                                      . Living resources.
20

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                                                                Citizens Advisory
                                                                Committee
Because public funds  are  used,  the  success of any estuary
program will ultimately  depend on citizen support. To generate
that support the citizenry, persuaded that it has a vested interest in
the outcome, must be involved in the entire program The citizens
advisory committee is germane to the estuary program because it
ensures representation  of the public voice  during all  program
phases  An educated, informed, and involved citizenry is the estu-
ary program's  most valuable ally. In  the  long run, many people
and corporations will be affected by measures taken to  maintain
and restore the estuary. These include, for example, levying addi-
tional taxes to  pay for sewage treatment  and sediment controls,
imposing changes in lawn care and agricultural practices, restrict-
ing some waterfront land uses, and placing stricter regulations on
dischargers

Although the CAC is the formal mechanism for public involvement,
it does not preclude the  necessity for a general public participation
program The CAC's role must be clearly defined by the manage-
ment committee (For specific guidance  on  setting up  a  public
participation program, see Appendix B.)
The  CAC reports to the management  committee. CAC  repre-
sentatives may sit on that committee and on the policy committee
The  CAC helps  to ensure that the  management committee and
estuary program staff include the public in the  decision-making
process, and integrate public  opinion and expertise into each
program phase The CAC recommends the most effective ways to
inform the public and solicit its participation It also identifies key
people  and organizations that can help  bring estuary-related
issues to the public's attention and build support for program ac-
tivities

The CAC ensures representation of public concerns while options
are fluid, rather than after data collection and analyses have been
completed and final decisions made. Public support for  imple-
mentation is more likely if the public has been involved throughout
program evolution The CAC engages in  the following activities to
fulfill its role-

  • Helps to establish program goals and objectives;

  • Participates in determining funding levels for program
    activities,

  • Comments on research priorities.

  • Reviews technical findings and analyses;

  • Helps develop implementation plans;

  • Assists with public participation activities; and

  • Educates user groups concerning the purpose and benefit of
    proposed programs
                                                                What Does the Citizens
                                                                Advisory Committee Do?
                                                                                            21

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  Who Are the Members of
       the Citizens Advisory
                Committee?
  Staff Support for the
            Management
              Conference
                                  The CAC may conduct some activities to obtain input from a cross
                                  section of interest groups about their goals,  objectives, and
                                  preferences related to environmental quality. Public meetings are
                                  one vehicle. Other activities may be designed to disseminate infor-
                                  mation and  secure comments from  various  representative
                                  individuals and groups about the scope, goal, and progress of the
                                  program. The numerous methods for this purpose include press
                                  releases, newsletters, and questionnaires. To accomplish specific
                                  objectives, the CAC may also establish special work groups, sub-
                                  committees, or task forces.
                                   Citizens are nominated  by the management  committee and
                                   appointed by the policy committee. The CAC should represent a
                                   broad  spectrum  of major resource groups, for example, fishing
                                   interests, farmers, and recreational users. It should also include
                                   representatives from various environmental organizations and
                                   citizens councils.  Equally important are  representatives from
                                   business and industry, such as lumberers, shippers, and steel and
                                   petrochemical manufacturers. Of course, representation will vary
                                   with the type of users prevalent in the estuary basin.

                                   Although each program will need to establish the specific criteria
                                   for appointees,  nominees generally should meet the following
                                   criteria:

                                      .  Serve as a spokesperson for a major user or interest group;
                                      .  Have experience in the development of water quality and
                                        resource management policy;
                                      .  Understand the technical and economic feasibility of the
                                        pollution control options under consideration; and
                                      .  Represent a group that is affected by the recommendations
                                        and proposed programs
                                   Funds to support the Management Conference and to develop the
                                   CCMP are provided through Water Quality Act appropriations.
                                   Portions of these funds should be earmarked for staff support to
                                   the Conference. It is up to the Management Conference, however,
                                   to determine the composition of the staff, how it will be hired, and
                                   who will direct its activities. Various options are available.

                                   A state project office may provide this support. The Conference
                                   may contract with a nonprofit organization, educational institution,
                                   or state/local entity to assume staff responsibilities on its behalf.
                                   By using the Intergovernmental Personnel Act (IPA), support can
                                   also be secured from EPA and other federal agencies, such as
                                   NOAA.
22

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The Conference ultimately should try to have staff with the follow-
ing expertise:

  • A program manager or staff director experienced in planning,
   operating, and budgeting, and sensitive to public concerns;
  • Experienced public participation specialists to serve as staff
   to the citizens advisory committee and as liaison with the
   public (Appendix B);
  • A staff member experienced in the development and
   evaluation of management strategies and with an In-depth
   understanding of major federal and state statutes and
   implementing regulations affecting water quality, coastal land
   use, and protection of living resources;

  • Biologists knowledgeable about marine or estuarine systems
   to help characterize the estuary and recommend corrective
   actions;
  • A chemist, toxicologist. or general environmentalist to
   support In the characterization phase; and
  • A statistician familiar with environmental modeling to help in
   the characterization phase.

The Management Conference - its committees, elected officials,
and the general public - form the management structure under
which problems  and   concerns  related to  the estuary are
addressed and, over time, resolved
                                                                                              23

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                                                                      Chapter
                                           Characterization  and
                                                Problem  Definition
Once the Management Conference has built a framework for iden-
tifying, negotiating, and solving problems, it is ready to embark on
other tasks.  The Conference  begins to "take the pulse" of the
estuary, determining the state of its health and the reasons for its
decline. The process entails examining symptoms for probable
causes, testing  hypotheses for actual causes,  and defining the
most pressing problems. Known as "characterization and problem
definition," this phase provides the objective basis used to
develop management strategies for the estuary's Comprehensive
Conservation and Management Plan
          Characterization is .. .(copy to come)
Generally, a Management Conference is convened because there
are obvious problems  in the  estuary. These may  include, for
instance, decline in a  popular recreational or commercial fish
species, contamination of beaches,  kills of fish, or  extensive
bloom of algae. Although these occurrences are often referred to
as "perceived problems,"  they actually are symptoms of water
pollution The  challenge to the Conference,  working with the
STAC,  is to separate these  symptoms from their causes or
sources Frequently, some symptoms may be  addressed by
regulatory agency actions while scientists examine data to deter-
mine the exact cause  All participants, expressing their different
economic, aesthetic, health, and recreational concerns, will help
determine which problems will be addressed during characteriza-
tion.

The scientific investigations and reports  resulting from charac-
terization must be translated into plain English,  telling a story
about the estuary that the public can understand. The importance
of this step cannot be stressed strongly enough.  The success of
an estuary program depends on public understanding  of the
estuary's problems and public support for enacting prescribed
remedies.
                                                           Setting the Course
                                                                                    25

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                  Scientific
       Characterization
                                       Scientific data are used during the characterization  phase as the
                                       basis for an integrated, systemwide assessment of each estuary.
                                       The assessment addresses historical trends,  present  conditions,
                                       and probable future trends if current practices are not modified. It
                                       is analogous to telling a story about the past, present, and poten-
                                       tial future of each  estuary. The results are used  to substantiate
                                       environmental problems, evaluate their causes, recommend future
                                       remedial and management  strategies, and  develop long-term
                                       monitoring plans.

                                       Estuary characterization relies primarily on existing scientific infor-
                                       mation, particularly historical data. Such information, which can
                                       be collected and analyzed relatively efficiently and cost-effectively,
                                       provides the most direct way to evaluate trends in estuarine condi-
                                       tions.  The  kinds  of  information  commonly used for estuary
                                       characterization appear in Table 3.1.
                                         Table 3.1-Common Kinds of Historical Information Used for Estuary
                                                   Characterization

                                              Pollutant Sources to the Estuary
                                                  •  Watershed geomorphology
                                                  •  Land use patterns
                                                  •  Freshwater input
                                                  •  Pollutant loadings
                                                    - Direct discharges
                                                    - Riverine discharges
                                                    - Nonpoint source runoff
                                              Circulation of Material in the Estuary
                                                  •  Weather patterns
                                                  •  Tides/currents
                                                  •  Salinity
                                                  •  Temperature
                                                  •  Sediment grain size
                                              Distribution of Chemicals in Estuarine Waters and Sediments
                                                  •  Organic carbon
                                                  •  Nutrients
                                                  •  Dissolved oxygen
                                                  •  Chemical contaminants
                                               Distribution of Biological Organisms in the Estuary
                                                   •  Plankton
                                                   •  Benthic invertebrates
                                                   .  Rsh
                                                   •  Aquatic vegetation
                                                   •  Endangered species
                                               Rates of Biological Processes
                                                   •  Primary production
                                                   •  Secondary production
                                                   •  Respiration
                                                   •  Commercial fishery catches
                                                   •  Recreational fishery catches
                                               Factors Important to Human and Environmental Health
                                                   •  Distribution of bacteria and pathogenic organisms
                                                   •  Prevalence of disease m fish and shellfish
                                                   •  Tissue contaminants
                                               Geographic Areas of Special Importance
                                                   •  Critical spawning or nursery habitats
                                                   •  Recreational areas
                                                   •  Beach closures
                                                   •  Shellfish harvesting areas
26

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 However, readily available historical data, which consists of infor-
 mation already computerized or collected by  local, state, and
 federal agencies, may not address the specific problems being
 investigated in each estuary. Historical data are also incomplete
 and limited to specific regulatory programs. To overcome these
 limitations, new sources of data are identified and information is
 collected from virtually all possible sources-scientists, academic
 and research  institutions, and public  health and living resource
 agencies.

 The data are screened for as much useful information as possible.
 Within  limits  set  by the  investigating scientists, information is
 extracted from the data to create  new data sets for  analysis.
 Because collecting new scientific information is generally quite
 costly, historical data are used to set priorities for the kinds of new
 information needed for the characterization effort. These data are
 also  used to  shape new  sampling and  monitoring  programs
 needed to define specific problems.
 Characterization, which occurs over two to three years, proceeds
 through the following major steps:

  • Identifying the most significant problems for investigation;
  • Collecting priority data sets;
  • Identifying data management support;

  • Screening priority data sets;

  • Determining estuary segments;
  • Analyzing data;

  • Considering significant gaps in available data;
  • Reporting results in both peer-reviewed technical
    publications and public documents; and

  • Preparing a characterization report.

The relationship among these steps is presented in Figure 3.1.
The first step in the characterization process is identifying the
most  important  environmental  problems  in the estuary.  This
activity is conducted by the Management Conference and, there-
fore, cannot  begin until  a management framework  is set up.
Because all the problems cannot be addressed, it is critical to rank
them so that effort and funding levels are allocated effectively. The
following key  questions are addressed when the Management
Conference defines and ranks environmental problems.

 • Is the perception of the problem accurate?

 • Does the problem influence a large part of the estuary?

 • Can the probable cause of the problem be identified''

 • Is it feasible to correct the problem?
                                                                  Characterization
                                                                  Steps
                                                                 Identification and Ranking
                                                                 of Priority Problems for
                                                                 Study
                                                                                          27

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                                                      Steps In Characterization
                                                    Identify Priority
                                                      Problems
                   Estuary Management I
                       Committee
                                        Collect Priority
                                           Data Sets
    Identify Data
Management Support
                                                    Screen Priority
                                                      Data Sets
                        Determine
                    Estuary Segments
                                                       Analyze
                                                        Data
                                                        Report
                                                        Results
                     Address Priority
                        Data Gaps
                                        Public Synthesis
                                          Documents
    Peer-Reviewed
Technical Publications
                                                   Characterization
                                                       Report
                                       Figure 3.1   Relationships among characterization steps.
                                     Overestimating the severity or significance of certain  problems
                                     can divert attention from those that actually deserve greater con-
                                     cern The presence of toxic contaminants in the tissue of fish, for
                                     example, may capture widespread publicity and interest because
                                     of its potential effect on human health. However, the incidence of
                                     such contamination may be limited to specific sites  On the other
                                     hand,  nutrient  enrichment, eutrophication, and resulting  dis-
                                     solved oxygen depletion may  have  far greater  systemwide
                                     impacts, affecting not only finfish  species but shellfish and crab
                                     populations

                                     Problems with a systemwide impact generally are ranked  higher
                                     than  those with localized effects   Furthermore, problems that
                                     significantly curtail the  designated uses of an estuary may be
                                     ranked high  Some problems may receive a high ranking because
                                     corrective mechanisms,  such as  regulatory   programs  and
                                     authorities, are already in place
28

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From a management perspective, simply knowing that a problem
exists is not sufficient reason to study it. It is also necessary to be
able to identify the likely cause, and to ascertain whether correc-
tive actions are feasible within reasonable  cost and other limits.
Tractable, or  manageable, problems generally should be ranked
higher than those with no apparent solution or those requiring an
inordinate amount of effort to correct.

After the four key questions for the known environmental problems
in an estuary have been addressed, the problems are  ranked to
identify which warrant highest priority. These are considered in the
remaining characterization steps.
The second step In the characterization process is the collection
of "priority data sets" that are

  • Relevant to defining the nature and extent of a priority
    problem;

  • Pertinent to specific parameters needed to define the
    problem;

  • Broad in temporal and spatial coverage;
  • Good quality, as indicated by a preliminary assessment; and
  • In a usable format.

Although extensive information may be available for a particular
estuary,   the  initial selection  criterion (relevance) ensures that
collection efforts focus only on data sets directly related to the
priority problems The second criterion (pertinence) further con-
fines  collection efforts  to data  sets  containing information
important  for characterization,  such as specific variables  and
sampling  periods.  The third criterion  (breadth of temporal  and
spatial coverage) emphasizes data sets with broad temporal or
spatial scales  as opposed to data sets that represent a narrow
time frame  or those that are highly site-specific. The fourth
criterion focuses on quality assurance to prevent questionable
data from influencing the analyses.  Finally, the  data must be
formatted for computer use.

       The goal of the data collection and selection
      process is to identify what combination of data
       sets best  provides the information needed for
                  estuary characterization.

Rarely will any single data set rank highly with respect to all selec-
tion criteria.  Instead, the goal of the data collection and selection
process is to identify what combination of data sets best provides
the information needed for estuary characterization.
                                                                  Collection of Priority
                                                                  Data Sets
                                                                                              29

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                                        To help identify the most important data sets, questionnaires fre-
                                        quently are sent to investigators and organizations. A sample data
                                        request form  used to  obtain  information related to  a priority
                                        problem in Long Island Sound appears in Figure 3.2
                                                       Long Itland Sound Data Characterization Oxygen
                                                       Depletion In Wattarn Long leland Sound
                                            1   LIS Document Reference Number
                                            2   Organization Contacted
                                            3   Principal Investigator
                                            4   Contact
                                            5   Telephone Number
                                            6   Address of Contact
                                            7   Citation
                                                 al Aulhor(s)
                                                 bIYear
                                                 c) Title
                                                 d) Journal/Rept
                                                 e) Volume  Number
                                                 0 Pages
                                            8   Sample. Survey Type
                                                 a) Station(a)
                                                 b) Synoptic Survey
                                                 c) Vertical Resolution
                                            9.   Measurement
                                                 a) Dissolved Oxygen
                                                 b) % Oxygen Saturation
                                                 c) Temperature
                                                 d) Salinity
                                                 e) Phytoplankton Pigments
                                                 f) Phytoplankton Counts
                                                 g) Inorganic Nutrients (Ammonium,
                                                   Nitrate, Phosphate, Silicate)
                                                 h) Organic  Nutrients (DOC, TOC. DON,
                                                   TON. OOP. TOP)
                                                 i) BOD. COD
                                                 l) Biological Rates (Primary
                                                   Productivity, Water  Respiration.
                                                   Sediment Respiration, etc I
                                            10   Data. Study Area
                                            11   Time Span of Data
                                            12   Status of Data
                                                 a) Ran
                                                 b) Reprint
                                                 c) Computerized
                                                 d) Database Name
                                                 e) Data Products
                                            13   Comments
Y/N
       Frequency/Resolution
Y/N
            Units
                 Cost
                                         Figure 3.2  Example of a form used to identify priority data sets for
                                                    use in estuary characterization.
        Identification of Data
       Management Support
                                         While key data sets are being identified, collected, and reviewed,
                                         each  estuary program should find a data management  system
                                         that can store large amounts of historical and future information
                                         related to the estuary's conditions The data management system
                                         supports two  primary functions. First,  it enhances the charac-
                                         terization  process by providing  extensive   data  storage  and
                                         analytical capabilities. It is thus a free-standing data base access-
                                         ible to  the scientific  community  conducting  characterization
                                         studies.  Second, it serves as a long-term archive that can be con-
                                         tinuously  updated.   The  data base  will  be  expanded with
                                         information from sampling and monitoring efforts to  determine
                                         whether  the  abatement  and control  programs  improve water
                                         quality and living resources
30

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In  developing  data  management  support  for  each  estuary
program,  existing systems are evaluated. Evaluation criteria in-
clude the following:

  • Ease of access and use;
  • Use of relatively standard hardware and software;
  • Capability of storing diverse kinds of information, such as
    physical, chemical and biological data; land use statistics;
    and point and nonpoint source records;
  • Data analysis features, including analyzing statistics and
    generating presentations like tables, graphs, charts, and
    maps;
  • Flexibility to adapt to changing needs; and
  • Cost of usage and maintenance.

The state  agency  responsible for  implementing the  estuary
program's findings should use an in-house existing data manage-
ment system. If an appropriate system is not available, however, a
new one may be developed. Sometimes the new system will com-
bine the best features of two or more existing systems.
After priority data sets have been collected and entered into the
data management system, they can  be accessed  as needed.
Before data sets are analyzed, however, they must be screened
(Figure 3.1).

The screening procedure is designed to review the quality of the
data and  to identify unusual values or missing information. For
example, nonexistent observations from important time periods or
sampling stations should be identified,  in addition, unusually high
or low data values can be isolated for closer Inspection.

Screening can be conducted by combining computerized checks
with experts' technical reviews. The results of the screening proce-
dure are included in each data set. They  help determine  which
data sets are appropriate for  the various evaluations conducted
during data analysis. Screening also helps identify insufficient or
missing information that may need to be addressed later  in the
characterization process.
Estuary segmentation -  partitioning an estuary into a series of
spatial units or segments - is a useful analytical tool. It permits
integrating an extensive  amount of environmental  information
when certain conditions, such as water temperature and salinity,
are  relatively  homogeneous within a  segment. During  data
analysis, historical information collected for each segment is com-
bined to represent the average set of conditions encountered in
the segment. In this manner, a data base consisting of hundreds
of stations can be reduced to a description of conditions based on
a relatively smaller number of  segments (Figure 3.3). Besides
                                                                  Screening Priority
                                                                  Data Sets
                                                                 Estuary Segmentation
                                                                                             31

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                                                       Estuary Segmentation
                Data Analysis
                                   Concentration
                                     Figure 3.3  Estuary segmentation permits reducing the variability
                                                from hundreds of data points to a simplified picture of
                                                estuary trends.
                                     facilitating data integration, segmentation also allows researchers
                                     to examine data based  on station locations of uncertain origin.
                                     This is particularly useful because the lack of information on exact
                                     station locations is a limitation frequently encountered with histori-
                                     cal data sets.

                                     In addition to  providing  a means  for summarizing data for geo-
                                     graphic stretches of the estuary, segmentation is important for the
                                     development of water quality models and the subsequent alloca-
                                     tion of waste  discharges into the estuary. Future  management
                                     actions will most likely set pollution load reduction goals segment
                                     by segment. The impact of  this scheme on the  affected dis-
                                     chargers may  be  significant. Therefore, a segmentation scheme
                                     will need to consider political boundaries and the locations of the
                                     dischargers, as well as physical features and hydrography of the
                                     estuary.
                                     Once the data are screened, they can be analyzed by scientists to
                                     answer specific questions about the relationships among  pollu-
                                     tants, pollutant loadings, and their effects on water, sediment, and
                                     living resources. The general objectives of these analyses are to:

                                        . Determine the temporal trends and spatial patterns related
                                          to the most pressing problems of each estuary;

                                        • Determine possible causes of these problems;
                                        . Provide an integrated description of the conditions
                                          encountered in each estuary; and
                                        » Identify significant, missing data that warrant additional
                                          monitoring or sampling.
32

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The identification of temporal trends-or changes over time-is
important  for recognizing  problems and suggesting potential
causes. The landings of a particular species of fish in an estuary,
for example, may  continuously decline over a 40-year period
(Figure 3.4). This trend suggests that the species may be adverse-
ly affected within the estuary, but it does not suggest the potential
cause. Nevertheless, the temporal trend of interrelated, suspected
causes,  such as overfishing, pollution, or habitat loss, can  be
compared  with the overall  trend  in fish  landings. If  there are
similarities  between a suspected cause and the decline in  land-
ings, the cause may be further  evaluated to determine whether it
was the actual reason for the  observed problem.  Generally,
characterization  efforts do not establish  cause-effect relation-
ships. Absolutes or  certainties are replaced with a philosophy that
accepts a preponderance of evidence.
                      Temporal Trend
              §
              1
               1950    1960
                     1970

                     Year
1960   19SO
              Possible Causal Factors

    Overfishing          Habitat Loss
                    i
                    .0
                  •*- at
                   01
                                       Pollution
                    (A
 1960

  \_
Yaars
        1990
                    Yaais
                            19SO   1960
                                         Year*
                                                 1990
  Determine If Further Confirming Information Is Available

 Figure 3.4  To suggest problem areas, temporal trends in
            important resources may be correlated with
            possible causal factors. Blue zone indicates
            comparison of possible causal factors to
            temporal trend in fish landings.
Spatial patterns  - relative locations    can also be used to iden-
tity problems and suggest possible causes. A gradient (that is, a
continuous increase or decrease) in  the  distribution of copper
concentrations in bottom sediments found near the head of an es-
tuary is illustrative (Figure 3.5). Close inspection of the gradient
might  show  that  concentrations  are  highest  immediately
downstream  from a city, but that  they decline  both  up- and
downstream as one moves farther away. Such a pattern suggests
                                                                                               33

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                                      that the  copper  contamination originates in the city, and that
                                      subsequent analyses should attempt to identify the exact source.
                                                              Spatial Pattern
                                         River
                                               Copper Concentration
                                                           High
                                      Figure 3.5  Example of a spatial pattern for copper concentrations in
                                                sediments found near the head of an estuary.
                                      Another analytical technique to determine the potential causes of
                                      environmental problems is an evaluation of relationships among
                                      environmental variables. The reduction of aquatic vegetation may,
                                      for instance, be cited as a  priority problem  in an estuary.  The
                                      association between declining vegetation and a second estuarine
                                      variable, such as the presence of nitrogen in the water column,
                                      could be examined (Figure 3.6). If there is a positive correlation,
                                      nitrogen could be the culprit.


                                                           Cause-Effect Relationship
                                                   50

                                                   40

                                       Percent     30
                                       Vegetated
                                       Stations     20

                                                   10
                                                                 I
I
                                                                0.5        1.0        1.5
                                                              Nitrogen Concentration (mg/L)
                     2.0
                                      Figure 3.6  Example of a potential cause-effect relationship: The
                                                association between declining vegetation and the presence
                                                of nitrogen in the water.
34

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In all these examples, the potential cause of a problem is identi-
fied  through association.  Although this  kind of circumstantial
evidence is valuable, it does not conclusively prove a cause-effect
relationship. The problem and potential cause could be associ-
ated purely by chance; both  could be the  result of yet another
variable. Confirmation of cause-effect relationships  usually re-
quires conducting field or laboratory experiments under carefully
controlled conditions.

Historical data sets for most estuaries differ in terms of factors like
temporal and spatial coverage, kinds of measurements, and level
of detail. Therefore, the analytical methods used for characteriza-
tion  generally  include   various  quantitative  and  qualitative
techniques.  Nevertheless,  the goal is to integrate a wealth  of
diverse information into a unified description of the past, present,
and probable future conditions in each estuary (without, of course,
exceeding inherent data limitations).
As historical data are being analyzed during estuary characteriza-
tion, various gaps in the historical data base are uncovered. Some
of these data gaps substantially influence data analysis and there-
fore must be addressed. It is not feasible to address every missing
link in the historical data base. Scientists must therefore rank this
missing  information  in   terms of its  importance to accurate
analysis and interpretation.  Once  they have determined which
information  is required,  they can  overcome  the  deficiency by
reevaluating existing data or by collecting new information.

There  may  be significant gaps  in  data  on temporal   trends.
Although a decline in landings of a species of fish may have been
documented between 1950  and 1980, for instance, similar infor-
mation may not have been summarized since 1980 (Figure 3.7).
Without these data, it would be difficult to estimate whether land-
ings continued to decline after 1980. This would be especially true
if the  number of  landings remained relatively constant  between
1970 and 1980.  To determine whether the problem still exists,

                      Historical Data  Gaps
(O
CD
1 '
1
.C
.2
IL.







' Newly Summarized
• 4 Historical Information
.
•:.•
•


1950 1960 1970
Year
V
o 'o " \
•• •• . I'-O

1 1


New sampling
conducted during
estuary program
may show
continuation or
reversal of
trend

1980 1990


                                                                   Consideration of
                                                                   Incomplete Data
 Figure 3.7  Missing information on the trend of parameters through
           time can be supplied by newly funded synthesis of
           previously collected data or new sampling.
                                                                                               35

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                                    scientists would  have  to identify and collect additional existing
                                    information on landings from 1980 to the present. If a source of
                                    information cannot be identified, the estuary program may have
                                    to undertake   its own  sampling program to determine  current
                                    conditions and any trends.

                                    Data for spatial patterns may also be incomplete. The presence of
                                    high concentrations of  copper in bottom sediments downstream
                                    from a city again provides an illustration (Figure 3.8). Assume that
                                    information on concentrations upstream from the city and down-
                                    stream from the  area of high concentrations is  not  available.
                                    Without it, scientists cannot characterize the spatial extent of con-
                                    tamination or determine whether the source of contamination is in
                                    the  city. Such information is essential to determine the magnitude
                                    and likely cause of the problem. Accordingly, the  acquisition of
                                    these data probably would  be given a high priority. New data
                                    could be collected at a  series of sampling stations located at
                                    increasing distances from the city and the area of high concentra-
                                    tions.
                                                Use of New Sampling Stations
                                                   To Fill Spatial Data Gaps
                                               Pollutant Concentration

                                             High
Low
New Stations
                                         Sampling New Stations Yields Following Results
                                     Upstream source with
                                     little dilution in estuary,
                                     or strong source in all
                                     areas (e.g., atmosphere
                                     or runoff).
    Source is city
          Source is city but
          pollutant is degraded,
          diluted, or sedimented
          by the time it reaches
          estuary.
                                     Figure 3.8  New sampling to fill in missing spatial data can yield
                                               important information about the source and extent of a
                                               problem.
                                      Insufficient evidence about a suspected cause-effect relationship
                                      can lead to a pressing need to obtain missing data. Again, the
                                      relationship between declining  aquatic vegetation and increased
                                      nitrogen concentration provides an illustration. This relationship
                                      could be due to the stimulative effect of the nutrient nitrogen on
36

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                 Correlation Shown by
                    Historical Data
                        Analysis
         •s.1
          Is
          f£
          §I
                 Nitrogen Concentration

                 Correlation Tested by
                Fertilization Experiment
                                         Water Surface

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            Evaluation of
        Institutional and
            Management
                Programs
                                   The reports provide evidence useful for:
                                      . Summarizing major environmental problems within each
                                        estuary;
                                      . Identifying suspected causes of as many of the problems
                                        as possible;
                                      . Recommending future remedial and managerial strategies
                                        to correct the problems; and
                                      • Developing a long-term monitoring program to evaluate the
                                        effectiveness of these strategies and to identify emerging
                                        environmental problems at an early stage.
                                   The scientific evaluation of the physical, chemical, and biological
                                   state of the estuary does not proceed in isolation While it is under
                                   way, a simultaneous evaluation of the institutional structures, in-
                                   cluding  laws,   regulations,  and  management  programs, is
                                   conducted This evaluation addresses federal, state,  and local
                                   laws, regulations, policies, and other institutional efforts  It looks at
                                   how regulations are being enforced, whether programs are being
                                   coordinated, and if resources are allocated and used effectively.


                                       A simultaneous evaluation of the institutional
                                       structures, including  laws, regulations, and
                                          management programs, is conducted.

                                   Despite the likelihood of some overlap, it may be best to organize
                                   the evaluation in three parts:

                                      . Water and sediment quality management, both point and
                                        nonpoint source pollution abatement and control;
                                      • Living resources management, including special protection
                                        activities;  and
                                      • Land and water resources management

                                   Then, in examining each of the three management areas, considei
                                   the following

                                      • Federal, state, and local laws and regulations that are in
                                        effect;
                                      . Existing criteria, standards, and regulatory control
                                        programs, along with their compliance and enforcement
                                        records;

                                      . Presence of needed regulatory authorities;
                                      • Support from management institutions, such as planning
                                        and natural resource agencies and their policies;
38

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 For each  management  area,  it would be helpful to develop an
 extensive list of laws, regulations, policies, control programs, and
 resources  at federal,  state,  and local  levels. Identify  gaps and
 inconsistencies.  Most  of the existing  regulatory  programs are
 directed toward point source management. Therefore,  determine
 how  well  these  programs  are working.  Specifically, assess
 whether issued permits are of good quality, inspections are being
 conducted, and  enforcement actions are taken when violations
 occur.

 Next, evaluate nonpoint sources of pollution. Find out whether an
 adequate  nonpoint  source  program  is  in  effect.  Are  other
 authorities  to control nonpoint source pollution needed?

 To improve management of living resources, inventory available
 and operational statutory, regulatory,  and zoning  ordinances.
 Sediment control or other point and nonpoint source require-
 ments may need strengthening to ensure that water and sediment
 quality  can sustain living  resources. Initiatives to protect these
 resources and their habitats may be advisable. Such protections
 may  include providing for  minimum fresh water flows during
 drought conditions or establishing  antidegradation  policies for
 habitats critical to spawning, nursery, and forage areas.

 Finally, examine how the various control programs are integrated;
 be sure that existing programs are not working at cross-purposes
 Resources  from each governmental level and program  should be
 brought to bear on  the  most serious problems.  Find  out  if
 programs  are cooperating  in   this  effort. Determine whether
 citizens are involved so they can help to ensure intergovernmental
 and interagency coordination. Some state and local governments
 may consider reorganizing their agencies to foster program inte-
 gration and appropriate targeting of efforts.

 During this  phase, it is vital to understand what actions are already
 being taken within the current institutional  framework. Further,
 environmental degradation can occur when  existing authorities
 are not being exercised, or activities and  resources are not
 focused on the right problem. It is also important to determine
 whether existing environmental regulatory programs are keeping
 pace with a growing population and its needs.

 Once this evaluation has been completed, the Management Con-
 ference summarizes the findings. These findings will help form the
 base  of information   needed  to develop  additional control
 strategies and to recommend initiatives.
The characterization report is a public education tool. Because it
describes the estuary's problems objectively and lays out a range
of potential solutions, the report must be widely read and under-
stood.  Scientific and  technical findings and  reports  must be
summarized in lay terms and presented clearly, using fact sheets
and visual aids The citizens advisory committee and public partic-
ipation staff should be enlisted to help make the characterization
                                                                 Characterization
                                                                 Report
                                                                                             39

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                                  report meaningful  to  the citizenry  The report's findings should
                                  also be presented at meetings and workshops for the public and
                                  for the mass media

                                  The characterization report tells the story of the state of the estu-
                                  ary. It describes both spatial and temporal  changes that have
                                  been caused by human activity;  natural climatic, biological, and
                                  physical changes,  and occasional major natural events  The
                                  report highlights the way the estuary used to be, the way it is
                                  today, and the way it might become if current trends continue
                                  Population trends are an important part of the report.

                                  Significant  population  growth   usually   leads  to  increased
                                  withdrawal of fresh water. Population growth  also results in addi-
                                  tional needs for sewage treatment; greater runoff from  paved
                                   surfaces, construction, and agricultural activity; and more pollu-
                                  tion from commerce and industry.
                                           The characterization report is a public
                                        education tool... that sets the stage for the
                                          formulation of the CCMP and its action
                                                          strategies.
                                   The characterization report describes changes in  land-use pat-
                                   terns, such as reductions in cropland,  pastures,  and forested
                                   areas Water quantity and flow levels needed to sustain important
                                   resources may also be addressed in the report. Hydrological infor-
                                   mation will be included There may no longer be a free exchange
                                   of fresh and ocean waters Pollutants may be trapped in the estu-
                                   ary, accumulating and changing the balance and function of the
                                   ecosystem  The report describes the estuary's major problems
                                   and suggests possible solutions based on objective evidence.

                                   Besides depicting the physical, chemical, and biological state of
                                   the estuary, the characterization report assesses whether existing
                                   institutional mechanisms are appropriate in light of the estuarine
                                   system. The report addresses current laws, regulatory programs,
                                   and governmental and nongovernmental institutions, pointing to
                                   gaps and needs for new authorities and efforts It may suggest a
                                   more strenuous set  of standards and criteria, stepped up enforce-
                                   ment actions,  or even a new regulatory agency

                                   The characterization  report sets the stage  for formulating the
                                    CCMP  and its action strategies  Therefore,  all  participants  in
                                   the Management Conference must be fully informed. They must
                                    understand the story the report tells and its implications for the
                                    future
40

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                                                                Chapter IV
              The Comprehensive Conservation
                                    and  Management  Plan
                                                      A Blueprint for Action
The Comprehensive  Conservation and  Management  Plan,
developed by the Management Conference, Is a blueprint for re-
storing and maintaining an estuary. It identifies the most pressing
problems in an estuary, and establishes goals and objectives for
resolving them. The CCMP prescribes specific actions to protect
and enhance water and sediment quality, living  resources, and
land and water resources. Designated  uses of the estuary are
protected by the plan's actions.
      Section 320(b)  of the Water Quality Act of  1987
      directs Management Conferences to develop "a
      comprehensive conservation and management plan
      that recommends priority  corrective actions and
      compliance schedules addressing point and  non-
      point sources of pollution to restore and maintain
      the chemical, physical, and biological integrity of the
      estuary, including restoration and maintenance of
      water quality, a balanced indigenous population of
      shellfish, fish  and wildlife, and recreational activities
      in the estuary, and assure that the designated uses
      of the estuary are protected —"
The first task of the Management Conference is to summarize the
characterization findings in "plain English." The conferees then
debate the merits of each problem and determine which problems
will be the focus of the CCMP. These are called priority problems.

Characterization findings also form the basis for developing the
environmental quality goals and objectives that each Conference
establishes for the estuary. Once these goals and objectives have
been  set,  the Conference  develops specific action plans to
achieve them.
                                                      Developing a
                                                      Comprehensive
                                                      Conservation and
                                                      Management Plan
                                                                           41

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       Components of a
         Comprehensive
      Conservation and
      Management Plan
                                    The action plans, which are the core of the CCMP, address three
                                    management areas, water and sediment quality, living resources,
                                    and land and water resources. Implementation activities in each of
                                    these areas stem from the action plans.

                                    Implementing action plans  is the key to estuary cleanup. To help
                                    ensure implementation, therefore, the following steps are recom-
                                    mended:

                                       . Disseminate and discuss the characterization findings with
                                         affected parties in the watershed.

                                       • Continue public information and involvement efforts to
                                         ensure support for the CCMP.

                                       • Integrate and  coordinate all activities for CCMP
                                         development and implementation; work with affected
                                         jurisdictions, agencies, and programs.

                                       . Select, by Conference consensus, priority problems to be
                                         addressed in the CCMP.

                                       . Establish, by Conference consensus,  environmental quality
                                         goals and objectives for the estuary.

                                       • Evaluate and select management activities.

                                       . Prepare action plans for controlling pollution and managing
                                         resources.

                                       • Secure commitments  to implement action plans.

                                       • Periodically review, evaluate, and redirect efforts as
                                         necessary while action plans are being carried out.
                                    The centerpiece of the CCMP consists of action plans for attaining
                                    the goals and objectives set  by the Management Conference.
                                    Supporting components are vital parts of the plan as well. Figure
                                    4.1 depicts the relationship among the CCMP components and
                                    the process the Management Conference should use to conduct
                                    an estuary program. Table 4.1 presents the essential components
                                    in a CCMP
                                                     Table 4.1 -CCMP Components

                                           "Plain English" summary of the characterization findings
                                           Statement of priority problems to be addressed in the CCMP
                                           Environmental quality goals and objectives for the estuary
                                           Actions plans for the management areas water and sediment
                                           quality, living resources, and land and water resources
                                           Supporting components
                                           - A plan for public information and involvement
                                           - Provisions for program integration and coordination
                                           - Provisions for periodic review, evaluation, and redirection
                                           - Provisions for the development of implementation plans
42

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                    (Management Conference
   Program
   Integration
   Provide for
   coordinating
   other existing
   public and
   private
   activities
Phase 1 -  Planning Initiative
         Establish Framework
         for Decision Making
Phase 2 —  Characterization and
         Problem Definition
Public
Information and
Involvement
Establish
ongoing
program
                                                       Monitoring
                                                       Initiate
                                                       short-term
                                                       and provide
                                                       for long-term
                                                       activities
Phase 3 - COMPREHENSIVE CONSERVATION
        AND MANAGEMENT PLAN (CCMPI
        COMPONENTS
               Summery of Characterization Findings


               Priority Problems
               Environmental Quality
               Goals and Objectives
               Action Plans for Pollution Control
               and Resource Management
               Supporting Components provide for
                  Public Information and Involvement
                  Program Integration
                  Periodic Review. Evaluation,
                  and Redirection
                  Development of Implementation Plans
               Phase 4 — Implementation of
                       the CCMP
 Figure 4 1 Relationship Among the CCMP Components
         and the Management Conference Process
The characterization report developed during Phase 2 describes
the  estuary's  current condition, historical trends, and projected
future conditions (Chapter III). A summary of the report's findings
is an important part of the CCMP. The summary highlights the
most significant  chemical,  physical, biological,  and  institutional
problems in an estuary. It should address the three management
areas — water and sediment quality, living resources,  and  land
and water resources. Each action plan is directed toward abating
problems in one or several of these areas. The summary is also an
important  tool for  public  education and participation.  It  is  a
springboard or building consensus for  the CCMP and its  imple-
mentation
                                                                          A Summary of the
                                                                          Characterization
                                                                          Findings
                                                                                                         43

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       Priority Problems
       Addressed in the
                      CCMP
                                     Although the characterization report includes all the problems that
                                     were identified in the estuary, the Conference must select those
                                     that the CCMP will actually address. This selection process entails
                                     considering costs and benefits  It also requires  assessing the
                                     length of time for problem resolution and the likely success of
                                     efforts. Using the criteria in Table 4.2, the conferees then rank
                                     priority problems. (The list of selection criteria is an expansion of
                                     those  used  during  characterization.)  After  conferees   have
                                     developed and recommended a remedial course of action for the
                                     highest ranked problems, other problems can be addressed.
                                                Table 4.2-Selection Criteria for Priority Problems

                                            Does the problem affect a number of resources and/or uses of the
                                            estuary?
                                            Does the problem adversely affect public health?
                                            Does the problem have a systemwide impact?
                                            Does the problem have a number of major local impacts of high
                                            priority to the general public?
                                            Is the problem of great concern to the public, major users, and
                                            political leaders?
                                            Can the problem be corrected through timely institutional or regula-
                                            tory mechanisms?
                                            Can the problem be controlled at reasonable cost with existing
                                            technology?
                                            Does the problem require further research, thereby precluding im-
                                            mediate action?
                                     Certain problems may be so complex that abatement or cleanup
                                     could consume all of an estuary program's resources In these
                                     cases, the Conference  should explore other funding sources
                                     Some  estuary programs may rely on  creative financing, while
                                     others may redirect existing resources to a priority problem or tap
                                     funds held by Conference members (EPA is developing guidance
                                     on how to finance estuary programs, which will include informa-
                                     tion on funding alternatives)

                                     Setting priorities requires great effort. After the characterization
                                     report has been released, the Conference holds workshops, meet-
                                     ings, and media briefings to educate all affected publics. The CAC
                                     and  the  STAC explain  the characterization findings, and  the
                                     management committee hears the concerns of citizens groups,
                                     users, and the regulatory community. Based on this feedback and
                                     other considerations,  the management committee then recom-
                                     mends which priority problems should be the focus of the CCMP.
                                     The policy committee is responsible for adopting management
                                     committee  recommendations and for securing  commitments of
                                     state and federal resources to solve the problems
44

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When Congress established the National Estuary Program under
the Water Quality Act, it mandated the restoration  and main-
tenance  of  the  nation's  estuaries   The  law provides  that
productivity is to be assured, and the needs of an array of users
are to  be accommodated. The  Management Conference  is
charged  with  achieving  this intricate  balance  by setting broad
environmental quality goals  that comply with the mandate of the
Act and the will of the people.
            Goals, Objectives, and Action Plans
     Goals are broad, long-term aims the Management
     Conference sets for the estuary.
     Objectives are more specific, shorter-term targets for
     attaining goals.
     Action plans are detailed programs for meeting goals and
     objectives, indicating who, what, where, when, and how the
     plans will be carried out.
                                                                 Environmental
                                                                 Quality Goals  and
                                                                 Objectives for the
                                                                 Estuary
                                                                Setting Goals
Goals are usually long term and broad in scope The Conference
establishes overall  goals related to the desired condition for the
estuary and its segments. To  determine what goals the  public
wants  to attain and will support, the Management Conference
presents options for public discussion. These may range from
maintaining current conditions to restoring the estuary to  a past
condition, or to restoring or maintaining pristine quality.

In one tributary where Whitewater sports are popular, for example,
the goal might be to maintain a  pristine condition In an industrial-
ized segment, it might be to maintain the current condition  by
preventing further degradation.  In yet another segment, the goal
might be to restore  wetlands to a previous, healthier condition.

Setting goals requires  the public to understand  the effects of
population growth.  Everyone must be aware that the needs of a
growing population increase pollutant loads, foster industrial and
commercial  development,  and create additional  demands on
water use. The  consequences of  population growth may be
habitat modification and further environmental degradation
Environmental  quality objectives, unlike goals, are specific and
shorter term. They are aimed at achieving broader, longer-term
goals. Achievable through the implementation of specific action
plans, objectives generally reflect the environmental criteria or the
preferred uses that the Conference considers appropriate and
desirable for various estuarine segments. Objectives undoubtedly
                                                                Setting Objectives
                                                                                           45

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        Action Plans for
  Controlling Pollution
           and Managing
                Resources
                                     will vary from one segment to another Typically, they are estab-
                                     lished on  the basis  of  preferred uses, standards,  and  permit
                                     activities to improve water quality Objectives may also be set for
                                     the other management areas  sediment quality, living resources,
                                     and land and water resources

                                     One of the goals in the Chesapeake Bay Program, for example, is
                                     to reduce point and  nonpoint sources of pollution to improve
                                     water quality,  thus sustaining the bay's living resources. Some 16
                                     objectives have been  set to reach that goal  Included is a commit-
                                     ment from Maryland, Virginia, Pennsylvania, and the District of
                                     Columbia  to  develop, adopt, and implement a basinwide plan
                                     that would reduce, by 40 percent, the nutrients entering the bay.
                                     Actions to meet this objective by the year 2000 will begin in 1988

                                     The Puget Sound Water Quality  Authority  provides another illu-
                                     stration of setting goals and  objectives One of  the Authority's
                                     long-term goals is to  protect consumers of shellfish from  conta-
                                     minants, maintain and enhance the abundance of shellfish, and
                                     control pollution so that, by 1990, closed shellfish beds can be
                                     reopened and additional closures  prevented

                                     To safeguard  consumers  and shellfish, the Authority has set
                                     specific objectives  and taken action to achieve them.  Besides
                                     instituting  pollution control programs to  protect  and  restore
                                     shellfish, it is testing  for toxicants in  certain  shellfish beds The
                                     Authority is also extending monitoring and certification efforts. In
                                     addition, it is attempting to further public education and involve-
                                     ment in the protection of shellfish, and to identify funding sources
                                     for shellfish protection programs
                                     To help achieve environmental goals and objectives, the Manage-
                                     ment Conference develops action plans directed toward specific
                                     priority problems Action plans should address the three manage-
                                     ment areas, as shown in Table 4 3 Each action plan should focus
                                     on a priority problem in one or more of the management areas
                                               Table 4.3-Focus of Action Plans by Management Area

                                            Water and sediment quality pollution abatement and control
                                            Action plans focus on point and nonpoint sources
                                            Living resources management, including specially protected areas
                                            Action plans focus on protection and restoration
                                            Land use and water resources management Action plans focus on
                                            set asides as well as special protective legislation and initiatives
46

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As the Management Conference designs the CCMP, it will con-
sider  available management activities to  meet  its goals  and
objectives.   Because   water   management  problems  are
widespread,  programs around the  country have tried  various
measures to tackle specific problems. Many of these measures
have worked successfully. The National Estuary Program intends
to publish "Management Approaches for Estuaries," a handbook
that will describe various methods other estuary programs have
used to manage specific environmental problems. This handbook
should provide assistance to Conferences as they assess  and
select management activities.

The steps to follow in preparing an action plan appear in Table 4.4.
At least one  specific action plan should be developed for each
problem the  Conference  elects to address.  Examples of action
plans addressing typical problems are presented throughout this
chapter.
                    Table 4.4-Actlon Plan Steps

      1.  State the problem, identifying the probable causes and sources
      2  State the program goals related to the problem, source, or cause
      3 Set specific objectives to attain the goals.
      4.  Evaluate available management activities.
      5  Select the activity that will work, that the public will support, and
         that can be implemented within reasonable time and resources.
      6  Establish specific action plans needed to abate and control the
         problem or protect the resource. Each action plan addresses:
         • WHO. Identify who will act, pay, and enforce; spell out roles
           and resource commitments for each participating agency,
           institution, and enterprise.
         • WHAT: Describe what will be done For example, specify
           numerically based load reductions and use designations in
           this location; describe what specific activities are necessary to
           reach them.
         . WHERE: Describe the location this action will affect.
         • WHEN: Include schedules.
         • HOW: Outline the procedure used to perform this activity
      7.  Implement and monitor results.
      8  Report on progress, costs, and results
      9  Review, reevaluate, and redirect as needed
Although action  plans should focus on the three management
areas, there is likely to be considerable overlap among them. To
protect a living resource, for instance, a nonpoint source action
plan may be called for.
                                                                                                   47

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Water and Sediment Quality
                                      Improvements in water and sediment quality usually require con-
                                      trolling point and nonpoint sources of pollution. Table 4.5 outlines
                                      the steps to follow in addressing this problem.
                                             Table 4.5-Steps in Addressing Water and Sediment Quality

                                             Identify pollutant loads and sources — > Set target load reductions
                                             Assess point and nonpoint source control programs — > Improve
                                             programs through additional actions
                                             Review designated uses — > Revise to protect human health, water
                                             and sediment quality, and living resources.
                                             Consider available management activities — > Select highest
                                             ranking activities
                                             Develop action plans — > Set schedules, commit resources
                                             Implement — >  Monitor, review, revise, refine, and redirect if
                                             necessary
                                      Point  sources  of  pollution,  which  expel   nutrients,  toxics,
                                      suspended solids, and microorganisms,  usually are abated by
                                      limiting the discharge  under the National Pollutant  Discharge
                                      Elimination System (NPDES)  permit  program. This program re-
                                      quires pretreating  effluents,  upgrading  treatment technology,
                                      reducing concentrations of pollutants in the effluent, and properly
                                      maintaining and operating all equipment at both municipal and
                                      industrial plants. Improved management and enforcement of per-
                                      mit programs will most likely be important for controlling  point
                                      source loadings in an estuary.

                                      Like point sources, nonpoint sources consist of nutrients, toxics,
                                      sediments, and bacteria. Instead of being discharged from an out-
                                      flow pipe of  an industrial or  sewage treatment plant,  however,
                                      these pollutants run off the land Nutrients and toxics usually come
                                      from agricultural land and from urban streets. Sediment is eroded
                                      from agricultural and urban sources and from construction  sites.
                                      Animal and poorly treated human wastes contribute to  high bac-
                                      terial levels.

                                      Many  management  practices can be used to control nonpoint
                                      sources of pollution.  They range from planting cover vegetation
                                      and forests to reducing the use of lawn fertilizer in urban and sub-
                                      urban  neighborhoods and cleaning city streets. They  may also
                                      include issuing NPDES permits for sources not traditionally con-
                                      sidered point sources. Construction activities, animal feedlols.
                                      storm drains, car washes, and laundry facilities, for instance, may
                                      be issued permits. For each one, however, the Conference should
                                      develop a specific action plan as part of the CCMP. Tables 4.6 and
                                      4.7 contain sample action plans that include point  and nonpoint
                                      source controls.
48

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           Table 4.6-CCMP Action Plan for Toxic Hot Spots
   PROBLEM
   PROGRAM GOALS
   OBJECTIVES
   COMPACTIONS

   Within One Year-
                   Toxic hot spots: Defined areas of sediments
                   contaminated with toxic pollutants with
                   associated effects on living resources.

                   Eliminate, within three years, current sources of
                   the identified toxic pollutants of concern.
                   Implement programs to mitigate effects of
                   historical loadings to restore biological
                   productivity

                   Identify and control both point and nonpoint
                   sources of the pollutants of concern.
                   Evaluate and implement cost-effective mitigation
                   methods for each site, including dredging,
                   capping, and stabilization.
                    Identify all industrial and municipal facilities that
                    may discharge, use, or store the pollutants of
                    concern Review NPDES permit status, daily
                    monitoring report data, and compliance history
                    Develop baseline monitoring program for
                    sediment chemistry and appropriate biological
                    indicators of toxicity

Within Two Years     Issue permits or revise and reissue permits where
                    appropriate.
                    Inspect facilities for NPDES permit compliance,
                    including proper operation and maintenance, and
                    best management practices Ensure compliance
                    with other federal and state laws for disposal
                    Implement baseline monitoring program
                    Complete feasibility studies of mitigation
                    measures and cleanup options

Within Three Years    Implement mitigation measures.

Beyond Three Years:  Continue monitoring program to determine the
                    effectiveness of the point source control program
                    to reduce current loadings and the effectiveness
                    of mitigation measures.

LEAD               State departments of the environment and public
RESPONSIBILITY     health.

COOPERATING       Environmental Protection Agency, Food and Drug
AGENCIES           Administration, and National Marine Rsheries
                    Service

RESOURCES         Redirection of existing resources and additional
                    funding for NPDES permit program  New
                    program for sediment monitoring, $2 million
                    annually Special funding for mitigation measures
                    under other appropriate federal legislation.
                                                                           Living Resources
                                                                           Management
An estuary's living resources range from fish and their spawning
habitat to microscopic phyto- and zooplankton at the bottom of
the food chain. Waterfowl and marshlands adjacent to the estuary
are also estuarine resources.  Through the citizens program and
the scientific characterization effort, the Management Conference
                                                                                                            49

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                                         Table 4.7-CCMP Action Plan for Loss of Submerged Aquatic Vegetation
                                         PROBLEM


                                         PROGRAM GOAL

                                         OBJECTIVES
                                         COMPACTIONS

                                         Within One Year.
                                         Within Two Years
                                         Within Three
                                         Years
                                          LEAD
                                          RESPONSIBILITY

                                          COOPERATING
                                          AGENCIES

                                          RESOURCES
Loss of submerged aquatic vegetation in two major
tributaries due to increased turbidity and
sedimentation from nonpoint sources
Restore submerged aquatic vegetation beds to
1950 levels in identified tributaries
Reduce nonpoint source nutrient and sediment
loadings to each tributary
Reestablish submerged aquatic vegetation where
water quality and clarity are sufficient to  support it.
Survey tributaries and identify areas where water
and sediment quality is sufficient to support
submerged aquatic vegetation
Identify tributary segments with highest nonpoint
source loadings of nutrients and sediments
Develop a nonpoint source control program for
each segment, setting targets for load reductions.
Develop and implement revegetation programs for
selected segments
Develop and implement systemwide survey
methodology for submerged  aquatic vegetation
Conduct annual surveys
Full implementation of nonpoint source control
program for selected segments.

Monitor segments for improvements in water
quality
State department of natural resources and water
pollution control agency.

Environmental Protection Agency, Soil
Conservation Service, and Rsh and Wildlife Service

Public and private organizations to conduct annual
surveys of submerged aquatic vegetation to
supplement aerial surveys
$500,000 annually for revegetation program.
Redirection of existing resources and  new funding
of nonpoint source abatement and control
programs in selected tributaries.
                                         determines which natural resources the public values most. It will
                                         also determine which ones are critical to maintaining and restoring
                                         the stability and diversity of the ecosystem.

                                         The public often  measures an  estuary's health by the state of its
                                         living resources.   Citizens  may voice concern, for  example, if a
                                         particular living resource like striped bass, oysters, or waterfowl is
                                         declining.  Because  such  declines  usually  connote a  greater
                                         problem, the cause must be determined

                                         Poor water  quality is often the reason. Destruction of habitat or
                                         modification of spawning,  nursery,  and forage areas  also stress
                                         fish and  wildlife. Overfishing  and  overharvesting,  along  with
                                         natural climatic changes and  disease, may  further affect living
                                         resources.
50

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Generally, the causes of a declining species or altered habitat are
complex. Although some causes may have been identified during
characterization, others may require additional study. In any case,
because the  recovery period for living resources is prolonged,
interim steps aimed at  suspected causes may be in order Addi-
tional actions can  follow once the actual causes  have been
discovered.

The preservation of living resources may require using an array of
protective strategies It may be necessary, for example, to control
commercial and recreational catches.  Wildlife and wetlands  or
other habitats may also need immediate protection

Enhancement strategies  may  be considered to supplement
protective strateges. These include stocking hatcheries,  planting
wetlands  or underwater grasses, and initiating  aquacultural
programs  Obviously,  such enhancements will require water and
sediment of acceptable quality. After the Conference has reviewed
and selected management activities, it designs, writes, and enacts
action plans. Sample action plans to mitigate typical problems and
protect living resources and shellfish appear in Tables 4 8 and 4 9.

In its plans to protect and restore living resources, the Conference
should also consider special protection areas, such as those set
aside under federal, state, regional, and local programs. Some of
these programs are mentioned in the following section on land use
and water resources management.

Some waters that  have exceptionally significant recreational  or
ecological features may warrant  special protection. Antldegrada-
tion policies may be developed for these waters Other measures
to  protect  exceptional areas include  setting higher standards,
severely restricting waste inputs,  designating no-discharge areas,
or limiting shoreline development. Such areas may be slated as
high priorities for study  and monitoring.

Protection  and enhancement of living resources require public
understanding not only of what is happening to the resource and
why,  but of the time necessary for recovery,  the ecosystem's
response to improvements will not occur overnight. Organisms
will need time to reestablish themselves through natural propaga-
tion or through human intervention like developing aquaculture or
hatcheries. The quality of the estuary will, however, have to be
able to sustain living resources.

Suggested  steps for managing living resources appear in Table
4.10.
                                                                                             51

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                                           Table 4.8-CCMP Action Plan for Disease and Contamination in Finfish

                                           PROBLEM            Observed liver lesions and mercury contamination
                                                                in flounder
                                           PROGRAM GOAL     Reduce mercury levels in commercial and
                                                                recreational finfish to meet all federal and state
                                                                standards
                                                                By the year 2000, reduce all sources of mercury by
                                                                80 percent
                                           OBJECTIVES         Review and revise water and sediment quality
                                                                standards for mercury to ensure adequate
                                                                protection of fish and wildlife in the estuary
                                                                Identify and rank all sources of mercury, and
                                                                develop management strategies to reduce source
                                                                loadings
                                           CCMP ACTIONS

                                           Within One Year
                     Review NPDES permits for all industrial sources of
                     mercury
                     Complete a basmwide analysis of all sources of
                     mercury and determine relative loadings from all
                     sources
                     Establish water and sediment quality standards for
                     mercury for each segment of the estuary Develop
                     wasteload allocations for each segment
Within Three          Review and evaluate existing water quality
Years                monitoring programs

                     Revise to include sampling for monitoring and
                     sampling  stations to correspond with fishery catch
                     data
                     Establish reporting network for commercial
                     fishermen
                     Reissue or revise all NPDES permits to reflect best
                     available technology and water quality-based
                     effluent limitations for mercury Where mercury
                     comes from noneffluent  sources, develop and
                     implement best management practices, conduct
                     quarterly inspections
                     Develop permitting strategies or best management
                     practices for all storm drains, combined sewer
                     overflows, and nonpomt sources of mercury
                     Implement strategy
                     Review monitoring and fishery data to determine if
                     mitigation and/or control activities are needed in
                     additional segments
 LEAD                State departments of natural resources, water
 RESPONSIBILITY      pollution control, and  health and public services

 COOPERATING       Environmental Protection Agency, Food and Drug
 AGENCIES           Administration, and National Marine Fisheries
                     Service
 RESOURCES         Redirection of existing resources for NPDES
                     permitting
                     Supplemental funding for establishing new
                     standards, $500,000 New funding for nonpomt
                     sources of mercury, $800,000 Annual funding of
                     fishery reporting network, $80,000
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Table 4.9-CCMP Action Plan for Bacterial Contamination of Shellfish

 PROBLEM           Some 30 percent of commercial and recreational
                     shellfish beds are closed due to bacterial
                     contamination from septic tank systems.

 PROGRAM GOAL    To reopen 50 percent of the closed shellfish beds
                     within three years.

 OBJECTIVES        Establish local ordinances on proper operation
                     and maintenance of septic tanks.
                     Plan for regular septic tank inspections.
                     Assess the need for, identify funding sources,
                     and develop a ten-year construction plan for
                     sewer extensions and wastewater treatment.
 CCMP ACTIONS

 Within One Year:
                    Develop and implement a public education
                    program on the proper operation and
                    maintenance of septic tanks, emphasizing water
                    quality effects.
                    Develop local inspection programs for septic
                    tanks
                    Develop and implement a routine monitoring
                    program for contaminated shellfish beds. Reopen
                    any uncontaminated beds.
                    Assess the need for sewer extensions to support
                    future development.

                    Assess monitoring data to determine whether
                    bacterial loadings havo been reduced Reopen
                    any uncontaminated beds.
                    Implement local septic tank inspection programs.

                    Assess monitoring data to determine whether any
                    further reduction in bacterial loadings has been
                    achieved. Assess effectiveness of control  actions
                    taken to date Reopen any uncontaminated beds.
                    Develop a ten-year construction plan, and identify
                    funding sources for the construction of sewer
                    extensions and/or wastewater treatment facilities.

LEAD               Departments of public  health and water quality
RESPONSIBILITY     control

COOPERATING      Environmental Protection Agency, and Food and
AGENCIES          Drug Administration

RESOURCES        New funding of $300,000 per year for three years
                    to conduct monitoring  program. Redirection of
                    existing programs to cover remainder of program
                    Obtain federal, state, and local funding for
                    construction of wastewater treatment plants and
                    sewer extensions.
 Within Two Years-
 Within Three Years:
     Table 4.10-Steps In Addressing Living Resources Management

        • Identify living resources of concern and determine causes of
          decline — > Set objectives to address causes
        • Assess control programs —> Improve programs through
          additional actions
        • Assess land acquisition programs — > Integrate federal,
          state, local, and private-sector plans
        • Review the estuary's designated uses — > Revise to protect
          living resources (fish, wildlife, habitat, and so forth)
        • Evaluate available management activities — > Select highest
          ranking activities for protecting or enhancing a resource
        • Develop action plans — >  Set schedules and commit
          resources
        • Implement — > Monitor, review, revise, refine, and redirect as
          needed
                                                                                                           53

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        Land Use and Water
   Resources Management
                                     To manage the use of land and water in the watershed, the Con-
                                     ference must determine why these resources are being adversely
                                     affected and how to prevent further major loss. Natural causes
                                     may be responsible for some of the loss  Other forces beyond the
                                     Conference's  control,  such- as  overwhelming  demands  from
                                     dramatic growth, in  population, may be  the cause. A serious
                                     drought in a watershed's already overextended supply of surface
                                     water may take many  years to overcome. Planning  ahead may
                                     help to reduce additional losses of land  and water resources.
                                     Table 4 11 outlines the steps that should  be taken in this manage-
                                     ment area.
                                          Table 4.11 -Steps in Addressing Land Use and Water Resources
                                                    Management

                                          • Identify problems and causes — > Set objectives to deal with them
                                          • "Assess existing laws and'programs — > Improve or initiate new
                                            ones
                                          • Consider available management activities — > Select highest
                                            ranking activities for managing land and water resources
                                          • Develop action plans for short- and long-term objectives and goals
                                            — > Set schedules, commit resources
                                          • Implement — > Monitor, review, revise, and, if necessary, redirect
                                     The  Management  Conference can  use  existing .regulatory
                                     programs and other mechanisms to control land and water uses.
                                     Among those worth  considering  are federal, state, and  local
                                     special protective laws and set  aside programs  that employ
                                     provisions of the following legislation and programs

                                        • Section 208 designated use authority;
                                        • Wild and Scenic Rivers Act;
                                        . Endangered Species Act;

                                        . Estuarine and Marine Sanctuaries;
                                        . Historic Preservation Act;

                                        . Private and public land banks, including agricultural
                                          easements,  conservation easements, wildlife refuges, and
                                          parks;
                                        . Critical, exceptional, or sensitive areas protective legislation;
                                        • Local zoning ordinances, and
                                        . EPA and state antidegradation policies for water quality.
                                     If, for example, freshwater inflow has been identified as a problem
                                     in  the   estuary, initiating  conservation measures,' developing
                                     reservoirs, or dredging to maintain minimum flows may be useful.
                                     Estuaries must often compete for fresh water. Needs for municipal
                                     water,  hydroelectric  power, and  agricultural irrigation projects
                                     must be balanced against  the  needs of an estuary. Table 4.12
                                     shows an action  plan aimed at  managing water resources when
                                     freshwater inflow is insufficient.
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           Table 4.12-CCMP Action Plan for Freshwater Flow
    PROBLEM

    PROGRAM GOAL



    OBJECTIVE



    COMPACTIONS

    Within One Year.


    Within Two Years



    Within Three Years



    Within Rve Years:


    LEAD
    RESPONSIBILITY


    COOPERATING
    AGENCIES


    RESOURCES
Insufficient flow of fresh water to the estuary.

To manage water uses in the watershed so that
estuarine resources are protected and
recreational needs can be met.

Develop a state water allocation scheme that
includes providing for sufficient fresh water flow
to the estuary
Develop a public policy that recognizes and
provides for estuarine uses as a "beneficial use."

Initiate research to determine the amount of
freshwater inflow needed annually and seasonally
for the estuary.

Develop a statewide water resources plan that
identifies sources of fresh water that could be
reserved for the estuary

Provide for upstream reservoir projects for
estuarine maintenance.

State departments of water resources and
environment, and state and private research and
educational institutions

U.S Water Resources Council, Department of the
Interior, Environmental Protection Agency, and
Corps of Engineers.

State legislative and private funding for research
and development ol water resources plan; federal
and state funding for reservoir construction and
maintenance.
Because the nation's population Is growing rapidly  in  coastal
areas, it has become increasingly necessary to plan  to  protect
land  and  water resources.  Unless protective measures are
adopted, population pressure and changing land use patterns un-
doubtedly will lead to further degradation  of these  resources.
Table 4.13 is a sample action plan aimed at stemming loss of wet-
lands.
The stated purposes of a CCMP are to restore and maintain the in-
tegrity of an estuary. To ensure this end, approval for the CCMP
and its implementation is crucial. Supporting components are
directed toward garnering support and commitments for carrying
out the CCMP, and keeping the  effort  on course. These com-
ponents are.

  • A plan for public information and involvement;

  • Provisions for program integration and coordination;

  • Provisions for periodic review, evaluation, and redirection;
    and

  • Provisions for implementation.
                                                                       Supporting
                                                                       Components
                                                                                                    55

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                                                 Table 4.13-CCMP Action Plan for Wetlands Protection
                                        PROBLEM

                                        PROGRAM GOALS

                                        OBJECTIVES
                                        COMPACTIONS

                                        Within One Year.
                                        Within Two Years
                                        Within Rve Years
                                        LEAD
                                        RESPONSIBILITY

                                        COOPERATING
                                        AGENCIES

                                        RESOURCES
Average annual wetlands loss of GO acres per year

To reduce the average annual rate of wetlands loss
to zero by the year 2000
Reduce the number of acres of wetlands lost per
year by more stringent application of existing
federal and state laws
Develop and establish programs to maintain and
restore wetlands
Develop a statewide wetlands management plan
that identifies wetlands priorities and management
actions
Identify wetlands critical to living resources or water
inflow control
Establish state, federal, or private acquisition efforts
Identify wetlands areas subject to intense
development pressure
Review local and state land use management plans
and permit applications
Develop and implement mitigation plans
Identify seasonal wetlands for restoration

Develop and implement mitigation plans to ensure
return of adequate freshwater inflow
State departments of natural resources and coastal
zone management

Fish and Wildlife Service, Environmental Protection
Agency, and Corps of Engineers

State legislative funding of land acquisition
program, $4 million
Local, state, and federal parks and wildlife refuge
acquisition programs, $10 million
Private sources, $5 million
             A Plan for Public
              Information and
                  Involvement
                                        A public participation strategy should  be designed to mobilize
                                        support for the CCMP and its implementation.  This  primer has
                                        stressed the importance of informing and involving  the public.
                                        Soliciting  the concerns and  opinions  of  affected persons and
                                        organized groups is essential to the collaborative problem-solving
                                        and decision-making processes.

                                        The Water Quality Act, in fact, specifically mandates that public
                                        participation must be provided for, encouraged, and assisted by
                                        EPA and the  states  Opportunities  to inform  and involve the
                                        citizenry occur through the CAC  and are broadened  by educa-
                                        tional materials, conferences, workshops, and public meetings

                                        Public acceptance,  or informed  consent, is necessary for CCMP
                                        implementation.   The public,  after all,  pays for cleanup.  Public
                                        pressure helps  to ensure that federal,  state, and local  commit-
                                        ments for program implementation are met. Moreover, restoration
56

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and maintenance of an estuary is a long and arduous task. It re-
quires public appreciation of the estuary's value for the citizens of
today and tomorrow. (For guidance on how to develop a public
participation program, see Appendix B.)
The key to  successful implementation of the CCMP may well
be the influence of the  EPA Administrator  and affected state
governors. Through their efforts, the expertise and resources of
other governmental programs - at federal, state, and local levels
- can be applied to this effort. But these officials cannot carry the
burden alone.

During all four phases of an estuary program, coordination among
jurisdictions,  agencies,  and  programs  is vital. This is particu-
larly important when responsibility for devising  action plans is
assigned. The Water Quality Act, specifically,  requires that plans
be drawn for coordinated CCMP implementation by the states as
well  as by federal and local agencies participating in the Con-
ference Each action plan, therefore, not only delineates roles and
responsibilities for Conference participants, but also provides for
the resource commitments to carry out the plan.

A specific role has been assigned under the Act to the National
Oceanic and Atmospheric  Administration (NOAA).  At the EPA
Administrator's request, NOAA is authorized to conduct monitor-
ing and research activities. Although the Act does not specify roles
for other federal agencies, they may also be involved in estuarine
protection.

In addition, many federal statutes  address this concern. Among
them are the Marine Protection, Research, and Sanctuaries Act;
the Coastal  Zone Management Act; the Fisheries Conservation
and  Management Act; the Resource Conservation and Recovery
Act;  and the Comprehensive Environmental, Reclamation, Com-
pensation, and Liability Act (known as Superfund).

State laws and regulatory programs also affect the restoration and
maintenance of  estuaries. Many counties and other  local sub-
divisions are engaged  in similar  efforts as well. Each estuary
program identifies and includes local, state, federal, and non-
governmental programs that are or could be involved in this effort.

Each Management Conference evaluates all the existing environ-
mental control programs affecting the estuary to be sure they  are
consistent with the goals and objectives set for the estuary. This
evaluation, which begins during the characterization phase, leads
to the identification  of  mechanisms that may  enhance each
program's effectiveness.  On the  other hand,  an assessment of
existing programs may indicate that environmental quality can-
not be achieved without supplementary actions. An evaluation
assumes the cooperation of all agencies; its results may depend
upon It.
                                                                 Provisions for Program
                                                                 Integration and
                                                                 Coordination
                                                                                            57

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    Provisions for Periodic
   Review, Evaluation, and
                Redirection
                                   As implementation of each action plan proceeds, each activity is
                                   reviewed, evaluated,  and  redirected as necessary. Therefore, a
                                   schedule for  Management Conference review, evaluation,  and
                                   redirection of  action plans is another important component of the
                                   CCMP. Crucial guidance  for  this process also comes from the
                                   results of scientific  research  and monitoring.  Research  and
                                   monitoring may be initiated  during the characterization phase,
                                   since additional data may be  required to identify problems and
                                   their causes. Usually, however, the CCMP  provides for any neces-
                                   sary long-term research and monitoring. The Act, in fact, requires
                                   monitoring  all management  actions  to  determine  their effec-
                                   tiveness. As components of  the CCMP,  plans for research  and
                                   monitoring should  address: why, who, what,  where, when,  and
                                   how.

                                   Providing for Research. As  noted earlier, research  efforts in an
                                   estuary generally consist of  applied  science.  Research may be
                                   short or long term Some problems  identified through charac-
                                   terization may require long-term research, while others can be
                                   alleviated  through  more  immediate abatement  activities.   As
                                   research results clarify a problem, the Conference may initiate a
                                   new program or modify an  existing effort. EPA, NOAA, other
                                   federal agencies, state and local governments,  educational institu-
                                   tions, and various private- and public-sector groups may sponsor
                                   research

                                   Establishing a Monitoring Program. Monitoring needs are iden-
                                   tified as part of each action plan. As actions are implemented,
                                   monitoring begins. Monitoring,  which is an essential part of the
                                   review and evaluation process, continues throughout the imple-
                                   mentation phase to measure effects  of actions and  indicate any
                                   new trends  Results of  monitoring many  demonstrate a need  to
                                   redirect efforts

                                   Although the  states are primarily responsible for monitoring results
                                   of actions, the Management Conference may ask for EPA's assis-
                                   tance. EPA may, in turn, enlist NOAA's support as provided under
                                   the Act.

                                    Modifying the CCMP. Because the  CCMP is a flexible manage-
                                    ment tool, it permits an  estuary program to  adapt  to changing
                                    circumstances and to apply  the lessons learned by experience.
                                    Some CCMP actions may be unsuccessful. New data may reveal
                                    unforeseen problems Earlier assumptions may have been incor-
                                    rect,  and  technological advances  may  enhance  cleanup
                                    capabilities  The resolution of some problems will free resources
                                    to tackle others.

                                    Furthermore, even though the CCMP is a document  reflecting
                                    consensus,  conflicts among jurisdictions, agencies at various
                                    governmental levels, and the public are inevitable. These will need
                                    to be resolved, possibly by modifying the plan
58

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                                                                Provisions for
                                                                Implementation
Scientific evidence  and public backing are vital for estuary
cleanup. Developing a comprehensive series of actions aimed at
cleanup is also essential. But it takes money and political will to
make cleanup a  reality. As part of the CCMP, the Management
Conference ensures that funding sources are identified and that
participating parties commit their moral support, political muscle,
and  financial resources to implementation. Agreements to this
effect  are  required.  The Administrator's approval  and  the
governor's concurrence lend additional importance to the CCMP.
Funds authorized  under the Act, along with state and local
resources, further support CCMP implementation.

Implementation has been a recurrent theme throughout the dis-
cussion of the CCMP. Action plans are essentially implementation
activities, and some of these activities may be initiated before the
CCMP receives formal approval. In such cases, funding may come
from the National Estuary  Program or from Management Con-
ference participants.

Implementation of the CCMP will certainly take longer than the five
years the Water  Quality Act  allocates for a Management Con-
ference. Therefore,  the Act  provides  that the  Management
Conference may be extended or reconvened to oversee imple-
mentation, redress problems, and address additional concerns. In
reality, it may take decades to restore and maintain those unique
and fragile resources, the nation's estuaries.
                                                                                           59

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                                                             Appendix A
    Federal Financial Assistance  Under the
   	National  Estuary Program
      This appendix of the  Estuary  Program Primer
      provides guidance on how to apply for and process
      federal assistance agreements. The primer, which
      describes the National Estuary Program's origins,
      statutory provisions, and approach, is designed for
      EPA's programs and regional offices, coastal states,
      and other interested parties. For more information,
      contact the EPA regional office.
Section 320(g) of the Water Quality Act of 1987 authorizes EPA to
award federal financial assistance to develop Comprehensive
Conservation and Management Plans (CCMPs) under the National
Estuary  Program  Projects geared to formulating CCMPs are
described in five-year work plans and in more specific annual work
plans developed by Management Conferences, which the  EPA
Administrator convenes. This appendix outlines guidance for
eligible applicants and  estuary program managers.  It provides
information on the following application and review procedures1

 • Estuary work plans,
 • Types of projects,
 • Who is eligible,
 • Types of assistance,
 • Selection criteria;
 • How to apply;
 • Review process,
 • Timeframes; and
 • How to get more information.
                                                    Applying for
                                                    Assistance

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Estuary Work Plans
    Five-Year Work Plans
      Annual Work Plans
   Types of Projects
      Who Is  Eligible
                                 Establishing long-term and annual estuary work plans ensures the
                                 efficiency and coordination essential to the collaborative problem-
                                 solving process of the National  Estuary Program. This work
                                 planning  mechanism encourages  annual evaluations of current
                                 and projected activities so that long-term plans can be modified or
                                 redirected as necessary
                                 One of an estuary  Management Conference's first  tasks is to
                                 develop and approve a five-year work plan that identifies and
                                 ranks priority actions required to complete the CCMP. Essentially
                                 a flexible planning tool, the five-year plan defines the scope of the
                                 overall estuary project and establishes the timeframe  and budget
                                 for carrying out specific actions.
                                 Each  year when the Office of Marine and Estuarine  Protection
                                 (OMEP) allocates the estuary's fiscal year funds, the Conference
                                 committees develop an annual work plan. The plan reflects what
                                 can realistically be accomplished within that year's budget. It con-
                                 tains priority actions selected from the five-year plan and, for each
                                 action, details specific tasks or projects to be carried  out during
                                 the year.
                                 Among the projects eligible for federal financial assistance under
                                 Section 320(g) are research  efforts, surveys, studies, modeling.
                                 and other technical work needed to develop the CCMP.

                                 A variety of tasks will be required as part of  developing the
                                 management framework, characterization report, and CCMP.  It
                                 will be  necessary, for example, to gather and analyze existing
                                 historical data from information previously collected in the estuary.
                                 Identifying the need for. and conducting, research to acquire new
                                 or additional data to address priority problems may also be rele-
                                 vant.  Perhaps the task will  be to increase  regional public
                                 understanding about the problems and complexities of the estuary
                                 and to solicit public involvement during the decision-making and
                                 management processes. A review and evaluation of new initiatives
                                 in water  and sediment quality  programs and in  living resource
                                 programs may be called for. All these types of projects are eligible
                                 for federal financial assistance.
                                 Eligible applicants  include state,  interstate, and  regional water
                                 pollution  control  agencies  and  entities;  state  coastal zone
                                 management agencies; interstate agencies; other public or non-
                                 profit private  agencies;  and  institutions,  organizations, and
                                 individuals. For-profit  organizations are not eligible for direct
                                 grants or cooperative agreements under Section 320 (g).

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Where Management Conferences have  been convened for a
particular estuary, the responsible EPA regional office can provide
preapplication assistance  As a rule, all proposals or work state-
ments respond to  the  priority tasks  identified in the estuary's
approved annual work plan, which the Management Conference
develops  Each  estuary program  handles its own  request for
proposals. Proposals are submitted to the EPA regional estuary
coordinator or to a state  project coordinator, if one has been
identified by the program. Appropriate advisory committees within
the estuary management  organization  and  the  EPA  regional
program will review and approve each proposal
Federal financial assistance  is awarded  under two categories
cooperative agreements and grants They differ only in the degree
of federal involvement during the project. Cooperative agreements
require substantial federal involvement. Grants do not. The appli-
cation form must clearly indicate which type of assistance is being
requested

Matching funds are required  The statute limits the federal share,
which  is the amount  of  EPA funds awarded to a recipient for a
fiscal year, to 75 percent The recipient's minimum 25 percent
match must come from other sources, such as a recipient's funds,
in-kind services or donations, or a combination of these Imple-
mentation procedures for these  match  requirements  will  be
established in Section 320 (g) grant regulations, to be proposed in
late 1988

Although National Estuary Program grants usually are funded on a
12-month basis, project periods may extend to 36 months. EPA's
award of assistance under the National Estuary Program depends
on annual congressional  appropriations and annual work plans
developed by the EPA regional program Therefore, EPA will con-
tinue making awards for one-year budget periods Applications for
assistance must be submitted annually during EPA's designated
application period.
The EPA Grants Administration Division has determined that the
National  Estuary Program projects are eligible for review under
Executive Order 12372,  "Intergovernmental Review of Federal
Programs" For more information  on the review process, appli-
cants should consult their state's office or the official designated
as the single point of contact  Because this is  a 60-day review
period, all applicants should seek such review well before EPA's
required dates for final applications
To ensure substantial EPA participation and oversight, assistance
under the National Estuary Program generally will be awarded in
cooperative  agreements.  Therefore,  the scopes  of work in
cooperative agreements must describe what EPA's involvement
                                                                Types of Assistance
                                                                Review Under Executive
                                                                Order 12372
                                                                Cooperative Agreements

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                 Grants
Selection Criteria
      How to Apply
   Review Process
                              will be, when and how it will be performed, and the person respon-
                              sible for carrying out EPA's part of the work. These provisions
                              should  be negotiated  between EPA and  the  applicant during
                              preapplication assistance, before the formal application  is sub-
                              mitted

                              During the final application review process, EPA may also deter-
                              mine that further involvement is necessary. If so, these provisions
                              will be added as "special conditions" before EPA offers the award.
                              Usually, awards under $10,000 may be made in the form of grants.
                              Such grants  still  require  products or  deliverables  or both.
                              Schedules must be clearly established in the statement of work.
                               Each  Management  Conference  will  approve  preapplication
                               proposals in accordance with the proposal's technical merit and
                               relevance to the objectives, projects, and tasks identified in the
                               estuary program's annual work plan
                               Applicants should obtain an application kit from their EPA regional
                               office. The kit contains the application form and other relevant
                               documents,  including  pertinent   regulations   EPA's  regional
                               estuary coordinator will provide preapplication assistance. The
                               completed application  should be submitted to the  appropriate
                               EPA regional program office for approval and award.

                               Statements of work in the final application must contain schedules
                               for progress reports and  products  (including workshops and
                               educational materials)  that will contribute findings and  recom-
                               mendations for management decisions. They must provide for the
                               presentation of project data and information in EPA prescribed for-
                               mats as  well as  specify  methods to  ensure ongoing  project
                               coordination  and problem resolution.

                               Because an informed public is so critical to the estuary programs'
                               success, the  National Estuary Program has established policy that
                               requires presenting all products and information in a form and for-
                               mat the public can readily understand. In addition, applicants must
                               demonstrate  that they have adequate resources to complete the
                               tasks described to meet work plan objectives
                               The regional program will review final applications, with approved
                               scopes of work, for funding. Basically, there are two levels of
                               review.  First, the  estuary  management and advisory commit-
                               tees,  along with the  EPA  regional  office,  review  proposals
                               submitted in response to the annual work plan. If a proposal is
                               approved, the applicant submits a formal, more complete applica-
                               tion to the EPA regional office. The regional office has the authority
                               to approve the application for EPA funding. As early as fiscal years
                               1988 and 1989, EPA regional programs entering Phase 2, Charac-
                               terization and Problem Definition,  will  have authority to  award
                               financial assistance.

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                                                                 Regional Review
After the appropriate estuary management and advisory commit-
tees have approved the proposal, the EPA project officer reviews
the final application, making sure it is complete and meets pro-
gram requirements

  • The EPA regional program office must make certain that.

  • Applications forwarded to the Grants Administration Division
    are complete,
  • Statements of work are consistent with the elements in the
    work plan and the program objectives,
  • EPA, advisory committee, and scientific peer reviews are
    adequate,
  • Schedules, progress reports, products and deliverables, and
    requirements for submitting project data are adequate, in
    National Ocean Data Center format, and in machine-readable
    form.
  • Products will contribute to the findings needed to develop
    management strategies, and
  • Stipulations for substantial federal involvement are included
Before  OMEP approves  funds for projects under the National
Estuary Program, it will review proposals to determine whether the
project meets national program goals and objectives. (Although
OMEP  may ask to see certain proposals, it generally  will not
review applications after the regions have recommended approval
and award.)  OMEP  will  also evaluate  whether the application
meets the criteria specified for regional review

OMEP is also responsible for

  • Coordinating the estuary program projects with affected EPA
    program offices and other federal agencies, such as the
    National Oceanic and Atmospheric Administration and the
    Fish and Wildlife  Service;
  • Ensuring that program activities are consistent with EPA
    policies, guidance, and regulations as well as with pending
    legislation and rules,
  • Identifying and ensuring scientific peer review within and
    outside EPA in areas that require special expertise, and
  • Identifying and providing state-of-1he-art techniques and
    methods for laboratory, field, and research investigations.
 Concurrence by the EPA Office of Research and Development
 (ORD) will be required at the regional level for all projects involving
 laboratory and field studies.  Concurrence should be secured by
 the ORD  representative on the scientific and technical advisory
                                                                 Headquarters Program
                                                                 Review
                                                                 Office of Research and
                                                                 Development Concurrence

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Quality Assurance/Quality
    Control Requirements
                  Checklist
              Timeframe
                                  committee. An ORD  concurrence form  is  available  from the
                                  regional office. The ORD representative will:

                                     • Make certain the project does not duplicate current
                                       EPA/ORD research projects or activities;
                                     . Evaluate whether the quality of science in the proposal is
                                       adequate; and
                                     . Determine whether the research protocols in the proposal
                                       are consistent with those ORD and EPA have established.
                                  The "General Regulations for Assistance Agreements" (30 CFR
                                  Sec. 30.302 [d]) stipulate that quality assurance/quality control
                                  plans are required for any projects  containing environmental
                                  measurements  Therefore, where appropriate,  each application
                                  must include a quality assurance plan certification. Valid quality
                                  assurance/quality control plans must be in place and certified by
                                  the regional quality assurance officer before EPA will fund the
                                  project. (For further guidance, see the EPA report, "Guidance for
                                  Preparation of Combined Work/Quality Assurance Project Plans
                                  for Bay Program Studies.")

                                  The EPA regional  estuary  coordinator  should  identify which
                                  projects require quality assurance/quality control plans and refer
                                  them to the regional  quality assurance officer before the region
                                  approves the application for funding. Some projects, like historical
                                  data collection or public participation, may not require a plan. In
                                  these cases, the regional quality  assurance officer will prepare a
                                  negative statement and submit it with the application.
                                  A checklist identifying the critical elements of a complete applica-
                                  tion appears in Figure A.1. The final  application  form should
                                  contain an  original signature. In addition, it should include a
                                  detailed  breakdown  of budget categories and the applicant's
                                  procurement system certification (EPA 5700-48). The application
                                  kit provides further information.
                                  Completed applications usually  must reach  the  EPA  regional
                                  program office by June 1 to be considered for fiscal year funding.
                                  However, earlier deadlines may  be established by the estuary
                                  program's Management  Conference.  Check  with the  regional
                                  program office for this information.

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   Figure A.1 -National Estuary Program Application Checklist for Assistance
             Agreements


	YES    NO    NA
 Preapplication assistance provided by regional office
 Proposal approved for funding by the management
 committee (date)	
 Proposal reviewed and approved by the scientific and
 technical advisory committee or designated work group
 (date)	

 EPA application form (Standard Form 4245700-33) (state
 and local agencies) or
 EPA application form 5700-12 (educational institutions
 and others)
   • Agency/organization name, address, and contact
     person, including phone number
   • Correct budget and project periods
   • Proposed funding dollars correct appropiate
     federal cost share (75 pecent) and non-federal cost
     share (25 percent)
   • Executive Order 12372 (replaces OMB Or A-95)
     requirements acknowledged
   • Official signature - original enclosed
 Budget
   • All budget categories properly identified and
     correctly totaled
   • Indirect cost rate and base shown, if previously
     negotiated, a statement of when and with what
     federal agency

   • Completed Procurement System Certification (EPA
     5700-48) attached

 Statement of Work
   • Clearly written statement of work attached, contains
     schedule for products and deliverables,including
     periodic progress reports to the region, state project
     officer, and management committee
   • Statement  of work discussion describes relationship
     between proposal and approved fiscal year work
     plan elements
   • Statement  of work contains requirements that newly
     generated data is in NODC format and
     machine-readable form
   • Separate pages of detailed project budget, project
     dollars justified with statement of work and reflected
     in total budget categories
   • Statement  of work contains "substantial  federal
     involvement- required for cooperative agreement(s)
 Quality Assurance/Quality Control
   • Quality assurance certification attached
   • Project officer's negative quality assurance
     statement  attached
 Special Conditions
   • Separate list of conditions of substantial federal
     involvement identified in statement of work and/or
     other negotiated special conditions
 Distribution of Form Application
   • Original plus three copies to Technical Guidance
     Branch coordinator
 Project Officer/Reviewer	Date

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For More Information
      EPA Contacts by
      Estuary Program
                                 Any questions?  If so,  please consult the EPA regional contact.
                                 Additional guidance is also available  in the Catalog of Federal
                                 Domestic Assistance, 66.456, "Comprehensive Estuarine Manage-
                                 ment." The catalog is available from the Government Printing
                                 Office, SSOM, Washington, D.C. 20402.
                                 Program                                 FTS/Commercial
                                 Albemarle/Pamlico Sounds	257-2126
                                    Albemarle/Pamlico Sounds Study   	(404)347-2126
                                    EPA Region 4
                                    4345 Courtland Street, N.E.
                                    Atlanta, GA 30365
                                 Buzzards Bay	835-3514
                                    Buzzards Bay Project	(617)565-3514
                                    EPA Region 1
                                    John F. Kennedy Federal Building
                                    Room 2203
                                    Boston, MA 02203
                                 Long Island Sound   	835-3550
                                    Long Island Sound Study	(617)565-3550
                                    EPA Region 1
                                    John F. Kennedy Federal Building
                                    Room 2203
                                    Boston, MA 02203
                                 Long Island Sound Study	264-2514
                                    EPA Region 2  	(212)264-2514
                                    26 Federal Plaza
                                    New York, NY 10278
                                 Narragansett Bay	835-3523
                                    Narragansett Bay Project	(617)565-3523
                                    EPA Region 1
                                    John F. Kennedy Federal Building
                                    Room 2203
                                    Boston, MA 02203
                                 Puget Sound  	399-0966
                                    Puget Sound Estuary Program	(206) 442-0966
                                    EPA Region 10
                                    Office of Puget Sound
                                    1200 Sixth Avenue
                                    Seattle, WA 98101
                                 San Francisco Bay/Delta  	454-0960
                                    San Francisco Bay/Delta Project	(415)974-0960
                                    EPA Region 9
                                    215 Fremont Street
                                    San Francisco. CA 94105

                                 New Programs Contact
                                    National Estuary Program	475-7102
                                    Office of Marine and Estuarine Protection
                                    (WH556F)	(202)475-7102
                                    Washington, DC 20460

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                                                                    Appendix B
                            Building An  Effective  Public
                                         Participation  Program
       This  appendix  of  the  Estuary Program  Primer
       provides guidance on how to establish and manage
       a public participation program. The  primer, which
       describes  the National  Estuary Program's origins,
       statutory provisions, and approach, is designed for
       EPA's programs and regional offices, coastal states,
       and other  interested parties. For more information,
       contact the EPA regional office.
Informing and involving the public and getting its support can be
the most difficult aspect of an estuary program, yet it  is the
cornerstone of a successful program. An effective public participa-
tion effort will help ensure implementation of the Comprehensive
Conservation and  Management Plan  (CCMP). This plan  is the
product of a collaborative problem-solving process in which key
members of the public have been fully engaged. The desired long-
term improvements in the estuary will affect daily life through
better septic systems, water conservation, additional taxes, or
limits on some property uses. Everyone in the water basin  needs
to understand his or her role as a user of the estuary Because so
much is at stake, it is important to put the best talent, adequate
resources, and full  program commitment into designing and
executing an effective process for full public participation.

This appendix provides guidance  on  what constitutes effective
public participation, how to design and structure a program, how
to carry it out, and what kinds of resources should be devoted to
it It will help programs meet the statutory requirement that  public
participation "be provided for, encouraged and assisted . ..." as
well as the  regulatory requirements of 40 CFR Part 25, "Public
Participation Under the... dean Water Act."
                                                          A Cornerstone of
                                                          Success

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         What Is Public
          Participation?
 Designing the Public
Participation  Program
                                        Section 101 (e) Federal Water Pollution Control Act
                                      Public participation in the development, revision, and en-
                                      forcement of any regulation, standard, effluent limitation,
                                      plan, or program established by the Administrator or any
                                      State  under this Act shall be provided for,  encouraged,
                                      and assisted by the Administrator and the States.
                                   Public participation in the context of the National Estuary Program
                                   means involving citizens in the decision-making process that the
                                   Management Conference oversees.

                                   Recognizing estuaries as commonly held treasures - productive,
                                   fragile, and enormously appealing places to live, recreate, and do
                                   business - the National Estuary Program has stressed the politi-
                                   cal  and social  ramifications  of  estuary  management.  This
                                   emphasis is expressed through  requirements for  an  effective
                                   public participation program. EPA believes that estuary programs
                                   will reach the implementation phase only with public  support. The
                                   Agency's  conviction  is validated  by  experiences  in  other
                                   programs.

                                   The goal of public participation is to establish the public consen-
                                   sus that will ensure long-term support and implementation of the
                                   CCMP. As the  Management Conference proceeds and the colla-
                                   borative process evolves, public consensus must be achieved at
                                   least during two phases: first, when priority problems  are identified
                                   and, second, when solutions and action strategies for implementa-
                                   tion are selected and adopted.

                                   Consensus signifies substantial agreement  among  the four key
                                   constituent groups: elected officials,  environmental  managers,
                                   scientists, and the public. These groups must concur that a partic-
                                   ular course of action is technically well-founded, feasible, fair, and
                                   most likely to succeed. Consensus also implies the willingness of
                                   program participants to work together and  to  compromise.
                                   Sometimes  participants will be unable to reach consensus.  At
                                   other times   -  when  enforcing  regulations, for instance -
                                   agencies will  have  to  carry out their legal responsibilities
                                   regardless of consensus. Nevertheless, agreement among these
                                   four groups is essential for general program direction  and the
                                   development of long-range courses of action.

                                   To achieve consensus, the public must have accurate, timely, and
                                   relevant information. It must be well-informed to participate intelli-
                                   gently in the decision making process.
                                   The Management Conference should develop a public participa-
                                   tion  work  plan  to ensure orderly,  informed,  and balanced
                                   participation.  Planning for public participation activities should
                                   occur  simultaneously with planning  other aspects of  the

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program - at the very beginning. Two steps should be taken to
design the work plan:

  •  Assess issues and politics.
  •  Determine information and participation techniques.
After this, a public participation work plan should be designed to
meet identified needs. The Conference may ask its citizens advi-
sory committee (CAC) to develop the work plan, or it may engage
a trained professional to complete this effort.
An assessment of policy issues and politics undoubtedly occurred
before the estuary was placed in or nominated for the national
program.  Staff should  review the materials gathered  during the
nomination process to develop a profile of the social, technical,
and political issues related to the estuary.

There are various ways to do this. By answering  the following
questions, the Conference can begin to identify the  organizations
that are interested in the estuary.

  • Are there major conservation groups, fishing associations,
    boating clubs, or businesses that regularly interact  with EPA
    and state agencies on water quality issues?
  • Do local newspapers consider the problems in the  estuary an
    issue?

  • Do citizen organizations or universities conduct public
    meetings or conferences on subjects related to the estuary?
  • Have elected officials used the health of the estuary as a
    campaign issue7

  • What do local environmental groups think about how the
    EPA and state agencies are implementating environmental
    protection laws?

The best and  quickest way to assess whether the  public  under-
stands the issues is through  informal  discussion.  First, talk to
interested people. Ask how they would rate the estuary's  condi-
tion Solicit their views on its major problems and their perceptions
about how government (at all levels) is addressing them. Keep
notes on conversations.

Determine which  groups are influential, and assess  public atti-
tudes about issues.

  • Do groups seem polarized on one or more issues?
  • Is there substantial agreement on a particular issue?

  • Is any environmental advocacy group recognized as
    especially effective?

  • Is there a coalition group that appears capable of getting
    other groups together?
                                                                  Assessing Issues and
                                                                  Politics

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Determining Information
        and Participation
             Techniques
                                The answers to these questions will help in planning a public parti-
                                cipation program after issues and political ramifications have been
                                assessed. The interviewees will form the nucleus of a  mailing list.
                                The kickoff meeting, described in Chapter II of the primer, is a par-
                                ticularly effective vehicle to answer  these  questions. Another
                                option is to assign, through a grant or cooperative agreement, an
                                organization to answer them.
                                 Evaluation of information tools and participation mechanisms is
                                 the second step in designing the public participation work plan.
                                 For example, it makes no sense to produce another newsletter if
                                 several good ones are circulating Research the existing public
                                 documents of agencies such as Sea Grant, Coastal Zone Manage-
                                 ment, Corps of  Engineers,  state water quality  and  resource
                                 agencies, Soil Conservation Service,  Cooperative Extension Ser-
                                 vice  and,  of course, EPA.  Find out about  their distribution
                                 channels and mailing lists.  In addition, examine the publications
                                 private groups are distributing.

                                 When planning the public information part of the estuary program,
                                 take advantage of  these and other existing communications chan-
                                 nels;  design the  program to complement, supplement,  and
                                 expand current efforts. New programs frequently are criticized be-
                                 cause they  are duplicative; with a little research, an estuary
                                 program will not make this mistake. Financial considerations are
                                 even more compelling reasons to determine what is already being
                                 done. There simply will not  be enough money to do everything on
                                 the agenda. Smart choices require understanding the total picture.

                                 To determine the most effective ways to  involve the estuary's
                                 citizenry, its trust and confidence in EPA and other agencies must
                                 be assessed. Trust must be built.

                                 Find out how the  active citizens and interest groups in the area
                                 make themselves  heard in  the policy arena Some groups attend
                                 public hearings; others prefer  informal meetings. Some citizens
                                 prefer  direct access to  the EPA  Regional Administrator, the
                                 governor,  and  other decision makers.  So  far,  most estuary
                                 programs have developed informal participation programs. Find
                                 out whether constituents are comfortable with this approach or
                                 would prefer more structured, formal arrangements. Consider the
                                 size  of  the area  and the  number of governments, citizens, and
                                 interest  groups that should be involved

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                                                                 Preparing a Public
                                                                 Participation Work Plan
To prepare a simple and flexible work plan:

  •  Define objectives;
  •  Foster both the information and participation activities
    necessary to meet them;
  •  Identify staff and budget resources; and
  •  Develop a schedule of activities.
Because the  public participation program must respond to and
support the overall estuary program, including each of its phases,
this process will be relatively fluid. As the program changes in
response to scientific findings, political issues, or funding restric-
tions, the public participation plan must be modified. The work
plan should be simple and flexible - a means to an end, not an
end in itself.
When designing the work plan, bear in mind that the public not
only must have adequate, timely information, but also must be in-
volved in the decision-making process. Every activity should be
clearly linked to the goal of achieving the consensus needed for
long-term support of the estuary program. Many expensive activi-
ties  have  been conducted  in the name of public participation.
These activities include educational films, exhibits, fancy publica-
tions, and programs for  school  children,  which sap  limited
resources and  do not  immediately or directly contribute to the
program goals. For instance, if a budget for public participation is
$100,000 or less annually, it will pay only for a basic program.

The following components are essential for a basic program:

  • An excellent experienced staff person;

  • A comprehensive mailing list;
  • A general program slide show;
  • One written information piece: newsletter, newsbulletin, or
    fact sheet series,
  • Public meetings; and
  • A defined role for the citizens advisory committee.

A credible public participation program with these six components
can be conducted for a reasonable sum.

Depending on the size of the geographic area, more staff may be
necessary. If additional resources are available, the basic program
can  be  expanded. Nevertheless, these six elements are neither
expendable nor interchangeable;  they form the foundation for a
public participation program.
                                                                 Making Public
                                                                 Participation Work

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    An Expert Staff Person
A Comprehensive Mailing
                         List
                                   While in no way usurping the need for management, policy, other
                                   committee members, or the staff director as spokespersons, the
                                   person responsible for the public participation program serves as
                                   the linchpin. Because this staff member will interact with all kinds
                                   of citizens and their organizations,  public speaking and  writing
                                   skills are vital. He or she must understand technical material and
                                   be able to translate it into  lay language for a variety  of interest
                                   groups. A good listener as well, this expert must be able to convey
                                   citizens' concerns to the Conference. Sensitivity to the biases of
                                   various interest  groups  and  an ability  to  put  those biases in
                                   perspective, while maintaining a neutral  stance,  are essential
                                   qualities. Understanding the workings of government  as well  as
                                   the problems of the estuary will help. Further, the public participa-
                                   tion expert supports other estuary managers, helping  them deal
                                   effectively with public groups and the media.

                                   There are several ways to organize and staff a public participation
                                   program. EPA or a state agency could provide for the public parti-
                                   cipation function, including an expert coordinator. The work could
                                   also be performed under contract. A grant or cooperative agree-
                                   ment  can be arranged with an agency like Sea Grant or with a
                                   nonprofit organization. All these arrangements have  been tested,
                                   with varying success, in the National  Estuary Program.
                                   Knowing who constitutes the public for an estuary is essential to
                                   conducting an effective public participation program  Identifying
                                   target audiences and creating a representative, accurate mailing
                                   list of  organizations and people will lay the groundwork for the
                                   information and participation activities. The mailing list will start to
                                   form as plans develop for the kickoff meeting. Although the groups
                                   undoubtedly will  vary in each estuary, the following should be
                                   included:

                                      . Conservation and environmental organizations;
                                      • Service, civic, and good-government groups;

                                      • Recreational boating clubs;
                                      . Commercial and recreational fishing associations;
                                      . Real estate firms and developers;
                                      . Agricultural businesses and farm groups;
                                      • Seafood packers and marketers;
                                      . Chambers of commerce, business, and industry;
                                      • Shippers and port-related groups;
                                      . Local government elected officials;
                                      • Federal and state legislators;
                                      • Federal, state, and local agency officials;
                                      . Scientists and educators; and
                                      . Media -  print, radio, and television.

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The mailing list may contain as many as 10,000 names. To main-
tain a list this large and to exploit its potential, the list should be
computerized. Coding and software that permit sorting by both
geographic area and  interest group will multiply the uses of the
list.

It is not enough, however, to have assembled a list of names. The
importance of maintaining  personal contact with  interest group
leaders, media representatives, and key legislators and officials
cannot be  overstated  Sometimes the job of the public participa-
tion staff will be to initiate contacts and  create opportunities for
communication between these people and other program person-
nel. Public participation staff will also need to keep participants
informed about work progress during the entire program. A slide
show,  basic program  information paper, and public meetings are
essential tools for initiating and maintaining contact with the target
audiences
Capitalizing on the old adage that a picture is worth a thousand
words, you may find that a good, straightforward slide snow is an
effective educational tool. It can translate technical, scientific, and
regulatory information into an intelligent and convincing explana-
tion of the need for an estuary program, its components, and how
the  program  may change the future  course  of  the  estuary.
Photographs depicting the state of the estuary, how it is used, and
the sources of pollution - along  with a pithy script - can help
introduce the estuary program to the public.

Remember that technical slides and slides cluttered with words
are inappropriate  for a basic public presentation. On the  other
hand, maps are an effective way to translate technical material for
a lay audience. A basic estuary map, color-coded  or used with
overlays to show which areas need protection, or where pollution
problems have been pinpointed,  is particularly useful if readily
identifiable reference points  are included. Although  tables and
charts  with technical data  should  be  reserved  for scientific
symposia, scientific findings summarized in bar and pie charts can
be very effective. The slide show should create a visual image of
the  estuary and convey a few significant  concepts about the
program.

A basic slide show has several advantages It will help ensure con-
sistency  in the delivery  of the  message, regardless of the
presenter or the audience. It precludes the need  to prepare a
speech for every meeting, and anyone affiliated with the estuary
program can use it easily.  If the presentation is informal,  it can
be tailored  to the specific audience — boaters and farmers, for
instance  - by adding a few slides

The presentation can also evolve during the course of the estuary
program. Initially, it probably will deal with broad issues and the
intent of the program. Later on, it can include basic summaries of
scientific findings  and suggested management actions. It should
contain  up to 80 slides, which can be presented in 10 to 15
minutes.  A script can  be read by the presenter, or a taped,
automated  presentation  can be  used.  A question-and-answer
period should be built into every presentation.
                                                                   General Program
                                                                   Slide Show

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One Written Information
                   Paper
         Public Meetings
                                 Information fuels the public participation program; people who are
                                 uninformed or misinformed cannot  participate effectively. The
                                 estuary program has an obligation to provide information about
                                 why the program is being conducted, what its goals are, what
                                 problems  it  is trying to address, the progress it is making and,
                                 ultimately, what sorts of solutions it is proposing.

                                 Generally, the  public will  be  less interested  in organizational
                                 details than in what substantive issues are being examined, how
                                 much money is being spent, and who may  be affected. Citizens
                                 will be interested, for example,  in the causes of the problem and
                                 possible solutions.   But details about  which federal or state
                                 agencies and  departments are involved will not engage them.
                                 Relevance to the audience should be the guide.

                                 Capturing public attention is the goal. If the estuary's problems are
                                 interesting, pertinent, and controversial, the media will cover them.
                                 Most  organizations  have their  own information pieces, such as
                                 newsletters, and they often sponsor conferences. Take advantage
                                 of all these. Contacting the media regularly, preparing short arti-
                                 cles for organizational newsletters, and speaking at conferences
                                 and workshops are effective communications tools.

                                 In addition, the estuary program needs a vehicle to deliver its mes-
                                 sage  directly to its target audiences. Newsletters, bulletins, fact
                                 sheets, and issue papers are commonly  used.  The logo and for-
                                 mat  should  be distinctive  and  identifiable with  the  estuary
                                 program. Newsletters should be nontechnical and fairly short. Six
                                 or eight pages .of well-written material every two or three months
                                 can be extremely effective. Printing and mailing are costly, so
                                 careful planning is essential. Do not allow newsletters, bulletins, or
                                 fact sheets to substitute for personal contact.
                                 Opportunities to provide information and interact personally with
                                 interested citizens occur frequently at organizational  meetings,
                                 special workshops, and conferences. Exploit these opportunities
                                 fully. The slide presentation can become the core of a traveling
                                 road show to publicize the estuary program.

                                 Public meetings fall  under two categories: regularly scheduled
                                 meetings of organized  groups,  to which  Conference  repre-
                                 sentatives are invited to speak, and meetings that the Conference
                                 organizes. The former are, by far, the wiser use of time. Dozens of
                                 organization meetings can be attended in the same time it takes to
                                 organize a  Conference-sponsored meeting. Other organizations'
                                 meetings have another advantage.  Conference representation
                                 conveys how  important  It is for the group to participate in the
                                 estuary program. The Conference substantially expands its out-
                                 reach potential by meeting people on their turf.

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A mailing  list should indicate when  the group meets and who
chairs the  organization. A public participation strategy should in-
clude meeting with at least two or three affected organizations
within each of the categories o1 interest groups in the estuary.
The Management Conference will create a citizens advisory com-
mittee to ensure direct citizen involvement in the policy-making
process  At explicit junctures in the estuary program, direct inter-
action among the various affected interest groups and between
those groups and program managers needs to occur. A formally
constituted advisory committee  is  an important way to facilitate
this interaction

There are many ways to operate a CAC The chairperson or other
CAC representative serves on the management committee or, in
some cases, on the policy committee. Some estuary programs are
experimenting with management committees that represent both
public and private interests, in contrast to those composed solely
of government agencies

CAC members  should be appointed by  the Management Con-
ference The CAC should consist of about 20 people who broadly
represent the estuary's user and interest groups It is advisable to
develop criteria  for appointees. Usually, each member should.

  • Serve as a spokesperson for a major user or interest group;

  • Have experience in the development of water quality and
    resource management policy;

  • Be knowledgeable about the technical and economic
    feasibility of some of the pollution control options being
    considered,

  • Be potentially affected by the management
    recommendations of the Management Conference, and
  • Be able to provide constructive advice and work with varying
    points of view in a committee setting

The Conference must establish a clear charge for the CAC - what
its purpose is and how it functions. The CAC's primary role is to
help see that the public participation goal  is met and that, through
public consensus, long-term support for CCMP implementation is
assured  It is critical that  the committee's charge reflects this.
Other specific functions of the CAC include-

  • Helping establish program goals and objectives;
  • Helping set funding levels,

  • Assisting with public participation activities;

  • Helping to communicate program activities to user groups;
  • Commenting on research priorities,

  • Reviewing technical findings and analyses; and
  • Helping to develop implementation plans
                                                                A Citizens Advisory
                                                                Committee

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                                    Making advisory committees work well takes both planning and
                                    skill. With committees composed of diverse interests, the potential
                                    for conflict is great. Committee members and staff may benefit
                                    from some training in meeting facilitation and agenda-planning.
                                    Further,  having by-laws and adopting Robert's  Rules  of Order
                                    generally help the committee function in a businesslike way.

                                    An essential step in creating an effective advisory committee is
                                    taking the time for members to become acquainted. Every busi-
                                    ness meeting should include some time to converse informally.
                                    Meetings must  be organized so that all committee members are
                                    encouraged to participate, but no one dominates.

                                    Staffing .a citizens advisory committee is a time-consuming, full-
                                    time job. If the committee meets four to six times annually, for
                                    example, providing direct support will require one to two days a
                                    week.  Staff work will include  organizing meetings, developing
                                    agendas, communicating with committee  members,  preparing
                                    background materials, and doing follow-up work.

                                    Although the committee chairperson can be expected to  take
                                    some responsibility for these tasks, the staff will need to do much
                                    of the work. Volunteer committees can accomplish more useful
                                    work if they are supported by strong staff and believe their con-
                                    tribution is worthwhile. People who serve on advisory committees
                                    generally have many commitments. If they think their time is being
                                    wasted, they will quickly lose interest. A clear charge for the com-
                                    mittee and good staffing are, therefore, extremely important.

                                    Providing direct advice to the program is not the CAC's only  role,
                                    however. As leaders of a wide variety of interest groups, advisory
                                    committee members are the hub of a network that may become
                                    an estuary coalition. If one of the public  participation program's
                                    goals is to help ensure long-term support and implementation of
                                    recommendations, the advisory committee should be an integral
                                    part of the management framework Selecting members carefully
                                    and meeting their needs will increase the likelihood that they and
                                    their organizations will remain involved.

                                    To supplement CAC's formal advice, the groups they represent
                                    will probably want to provide their own input. Moreover, program
                                    managers need to recognize that a small committee, regardless of
                                    its  quality, can never represent every  viewpoint. So  program
                                    managers should  be open to input from other citizens. Encourag-
                                    ing broad public involvement means going beyond the CAC. If this
                                    is done well,  it will facilitate  the development  of permanent
                                    networks and coalitions that are essential to sustained implemen-
                                    tation of resource management programs.
10

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                                                                  Resources
A commitment to effective public participation requires dollars as
well as staff. A typical program budget may be broken down as fol-
lows:
    Item(s)
Percent of Budget
    Staff salary and fringe benefits      	30
    Secretarial support (half-time)	10
    Writer (half-time)	-	14
    Slide show graphics and production     	   4
    Newsletter (quarterly)  .        	15
    CAC meeting support and travel   	10
    Stafftravel  	   4
    Mailings, copying, office support, postage,
    and other miscellaneous expenses	8

    Percent Total	95%
This leaves 5 percent for additional activities, such as a program
kickoff event or a boat ride,  press  conference, workshops,  a
program logo and brochure, or a professionally produced public
service announcement The budget assumes that one of the parti-
cipating agencies can provide support services like computer time
for the mailing list More elaborate activities, such as films, publica-
tions, citizen monitoring programs, and educational programs for
school children, clearly exceed  this budget.

Additional activities may be funded and conducted by participat-
ing  agencies, private organizations,  and  foundations  A  key
responsibility of the Management Conference is to identify and ob-
tain  new and  innovative  sources of funding  for work  plan
elements. For public participation,  members of the CAC should
place this objective on  their agenda All agencies have some
money budgeted for public information materials  Many private
groups conduct excellent educational activities. Coordination with
these programs can expand the outreach capability of the estuary
program.

In summary, the goal of the estuary program is to develop viable
management strategies that will ensure protection of the estuary's
resources. Legislatures,  executive agencies, and public interest
groups must  cooperate to define policy priorities, initiate legisla-
tion,  appropriate funds,  and implement  actions.  Given  the
complexity of the issues related to estuarine management, it will
not  be  easy. The  guidance provided here will,  however,  help
program managers design an estuary program with a high prob-
ability of success.
                                                                                             11

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                                                                  Appendix C
                        Using  Finfish As Indicators  of
                                          Toxic  Contamination
       This appendix  of  the  Estuary Program Primer
       provides guidance on using finfish to indicate health
       or stress in an estuary and to monitor changes or
       trends in the estuary The primer, which describes
       the National Estuary Program's origins,  statutory
       provisions, and approach, is  designed  for EPA's
       programs and regional offices, coastal states, and
       other interested parties. For more information, con-
       tact the EPA regional office.
Since 1985, the public has voiced strong concern about the high
incidence of diseased finfish in the nation's estuaries. When EPA
tried  to determine  the  environmental  significance of this
phenomenon, it found no consensus within the scientific com-
munity  Consequently, in July 1966, EPA's Office of Marine and
Estuarine Protection convened a workshop to determine if a set of
scientifically appropriate, cost-effective finfish indicators could be
identified and  used  to  assess whether toxic contamination in
estuaries significantly affected  human  health and ecology.
Workshop findings led EPA to develop guidance for using finfish
as indicators of estuarine health or stress and for monitoring the
estuary. The workshop's report, "Proceedings and Summary  of
the Workshop on Finfish As Indicators of Toxic Contamination," is
available from the National Estuary Program.
The first task for workshop participants was to develop, evaluate,
and rank criteria related to finfish indicators so that the criteria
would be useful in estuary programs The recommended criteria
appear in Table C 1
                                                         EPA's Workshop
                                                         On Finfish As
                                                         Indicators of
                                                         Toxic Contamination
                                                         Setting Criteria

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                                        Table C.1 -Criteria for Using Finflsh As Indicators of Toxic Contamination

                                          The following criteria are essential
                                             •  Causality There must be an unequivocal cause and effect
                                               relationship between toxic pollution and the indicator
                                             •  Cost-effectiveness The indicator must be affordable and provide
                                               enough data to warrant the amount of money spent
                                             •  Useability Laboratories throughout the country must be able to use
                                               the indicator

                                          The following criteria would also be helpful
                                             •  Specificity
                                               - The method should be pollutant-specific That is, its use should
                                                 indicate the effects of a specific pollutant or class of pollutants
                                               - The method should be species-specific  That is, it should be
                                                 applicable only to one or a limited number of fish species
                                             •  Applicability to small or large spatial scales
                                               - The method should permit identification of small areas of
                                                 contamination within the estuary
                                                                       OR

                                               - The method should also permit locating the effect of
                                                 contamination in large areas of the estuary
                                             •  Usefulness as an early or late indicator
                                               - The method should be usable as an early indicator of toxic
                                                 contamination That is, it should be sensitive enough to
                                                 demonstrate an effect after brief exposure to low concentrations
                                                 of pollutants
                                                                       OR

                                               - The method should be usable as a late indicator That is, it
                                                 should have a low degree of sensitivity and be capable of
                                                 demonstrating an effect after prolonged exposure to high
                                                 concentrations of pollutants
              Highlights of
     Conclusions About
      The Usefulness of
   Finfish  as Indicators
Screening Across Estuaries
   Human Health Indicaiors
                                        The following discussion highlights workshop conclusions regard-
                                        ing the usefulness fmfish as indicators of toxic contamination
                                        Historical data on the abundance and distribution of fish popula-
                                        tions and the concentration of contaminants in fish generally are
                                        readily available  Therefore, these parameters are the most useful
                                        early screening tools  The use of other indicators is more limited
                                        because historical data are usually unavailable Furthermore, cost
                                        and time considerations preclude collecting large amounts of field
                                        data during the screening phase
                                        Concentrations of contaminants in tissues, or tissue residues, are
                                        useful  indicators of human  health  effects  Lesions, tumors, and
                                        other histopathological changes are not useful for this purpose

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 Scientists participating in the workshop were reluctant to con-
 clude that any single measure of fish health could be used as a
 definitive indicator of an ecosystem's health. However, if several
 indicators demonstrate change in a fish population, it is general-
 ly safe to assume that the ecosystem has been affected. This
 assumption should  be strengthened  by  considering effects on
 organisms at other  trophic  levels,  and by directly measuring
 contaminant levels in the environment.
 In a trend monitoring program, the use of finfish as indicators of
 toxic contamination is limited for three reasons: (1) some methods
 still need to be verified in the field; (2) fish move around; and (3)
 fish  are very active as  they  undergo  detoxification. Other or-
 ganisms, such as bivalve mollusks, are better indicators on a small
 spatial scale because they are less subject to these constraints.
 Finfish may, however, be more suitable for future studies in which
 the objective is to assess toxic stress over relatively large  areas,
 such as an entire estuary.
 Enzyme and immunological tests are especially useful as early
 warning signs of toxic stress. They can also be employed to indi-
 cate the recovery of fish from toxic stress. Unlike lesions, death, or
 population changes, the effects of toxic contamination measure-
 able by these tests appear sooner, and at lower levels and Shorter
 lengths of exposure to pollutants. These effects are reversible as
 the fish recover from stress. Recovery can be measured in the field
 in less time than the life cycle of the species being observed. The
 effects of stress must, however, be measured at appropriate times
 during the species' life cycle.

 Gross pathological and  population changes  appear over  the
 longer term. Such effects  indicate a highly disturbed ecosystem
 and suggest that fish have been exposed to high levels of pollu-
 tants for relatively long periods.
In order to use indicators in developing regulations or permit re-
quirements, EPA must establish a causal relationship  between
finfish indicators and toxic contamination. This will require further
research because finfish indicators are not yet refined enough to
prove such relationships.  Therefore, it is too early to conclude
that a particular finfish disease or population effect was caused by
a particular environmental pollutant. Standard laboratory testing
for toxicity is still needed.
                                                                   Fish Health Versus
                                                                   Ecosystem Health
                                                                   Indicators
                                                                   Trend Monitoring
                                                                  Early and Late Indicators
                                                                  Of Toxic Stress
                                                                  Establishing Causal
                                                                  Relationships As a Basis
                                                                  For Regulatory Action

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    Recommendations
For the Use of Finfish
 Indicators in Estuary
               Programs
                                  Using only field data, EPA cannot expect to establish causal
                                  relationships between a specific pollutant and a specific adverse
                                  effect for any type of organism. Finfish indicators are, neverthe-
                                  less, a useful monitoring  tool. If estuary managers  use several
                                  indicators that  lead to the same  conclusion, they  can gather
                                  enough evidence to warrant some type of action, although it may
                                  not be regulatory action.
                                   Using historical  data, program  managers whose estuaries are
                                   known or believed to be stressed by toxic contamination should
                                   attempt to establish baseline conditions. Baselines should be set
                                   for water and sediment concentrations of toxic pollutants, the
                                   abundance  and  distribution of finfish, and the levels of tissue
                                   residue.
                                     The use of a single finfish indicator is insufficient
                                      to evaluate the ecological significance of toxic
                                     contamination .... several indicators should be
                                                   used simultaneously.
                                   Monitoring should be conducted to determine the current loca-
                                   tions and spatial  extent of severe  effects, and to identify the
                                   specific pollutants. The use of a single finfish indicator is insuffi-
                                   cient   to   evaluate  the  ecological   significance  of  toxic
                                   contamination. The workshop's  scientists recommend  using
                                   several  indicators simultaneously. They also  recommend that,
                                   depending on the stage of the program and the resources avail-
                                   able, managers should select indicators from  high- or low-level
                                   suites, discussed below.

                                   A suite is a group of indicators that should be used to evaluate the
                                   significance of toxic contamination.  Low-level suites employ
                                   methods that rely on historical  data. These suites  are useful for
                                   problem identification and assessment. High-level  suites require
                                   collecting new information in the laboratory or in the field. Useful
                                   monitoring tools, high-level suites not only indicate the nature of
                                   the problem but  also enable managers to select methods for
                                   resolving it.

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                                                                  Indicators in the
                                                                  Low-Level Suite
Finfish indicators in  the  low-level  suite are useful primarily for
making nationwide comparisons of estuaries, and for identifying
regional problems. The objective is to assess, on a preliminary
basis, the extent and  severity of ecological effects caused by toxic
contamination.  Because  these indicators  can be  applied  to
analyze existing information, they are particularly appropriate for
the early stages of estuary programs.  During Phase 1, the Plan-
ning Initiative, they  can  be used  as  evidence in defining and
ranking problems  to be addressed by the Management Con-
ference. During Phase 2, Characterization and Problem Definition,
they can be used to establish status and trends.

The following indicators are from the low-level suite.

Sources of information. Information about problems related to
toxic contamination,  such as fishery closures, is compiled from
various sources. These include newspaper articles, anecdotes,
published  reports, and newsletters.

Gross pathology. Reports of obvious anatomical abnormalities
like fin erosion, skeletal deformities, and tumors help to identify the
presence of a problem.

Behavioral  abnormalities.  Changes  in   behavior,  such   as
avoidance or attraction of fish to contaminants, can be measured
by comparing the  reactions of fish before and after they are ex-
posed to the  test material. Other behavioral changes, for example
erratic swimming  or lethargy,  may indicate specific modes of
toxicity like neurological or metabolic dysfunction.

Distribution  and abundance.  Profiles of the spatial distribution
and abundance of a species may be directly related to mortality
caused by exposure to toxics, or to behavioral changes  like
avoidance and attraction cited above.

Tissue residues, especially in  commercial species. Fish tissue
should be analyzed for the concentration of some or all of the  129
priority pollutants.  Bioaccumulation of certain substances in  fish
indicates not only that the contaminant is in the environment, but
that it may potentially threaten the environment and human health.
Finfish indicators in the  high-level suite are useful  primarily for
longer term monitoring studies.  Monitoring is  conducted in tar-
geted studies to answer specific scientific or managerial questions
raised during the problem definition and characterization phase.
These indicators are also useful  biological monitors of health or
stress in the estuary. Because of their sensitivity, they  may be
used to determine the  effectiveness  of management  actions.
Methods  in  the  high-level  suite require  collecting  specific
laboratory or field data.
                                                                  Indicators in the
                                                                  High-Level Suite

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Establishing Baselines and
           Reference Areas
                                   In addition to the high-level indicators discussed below, certain
                                   low-level indicators  - tissue  residues and fish distribution and
                                   abundance, for example - should also be considered for use in
                                   monitoring studies

                                   Macrophage triad. The macrophage triad is a useful early warn-
                                   ing of general stress. Macrophage cells exhibit three behaviors, or
                                   responses, that have demonstrated a direct relationship to the
                                   presence of toxics.

                                   Enzymes (mixed function oxidases,  metallothionein).  Certain
                                   enzymes or proteins may be produced by an animal as a result of
                                   exposure to various classes of pollutants. Immunological methods
                                   measure the presence and amounts of the enzymes or proteins
                                   produced

                                   Hematology. Routine clinical tests of blood components can
                                   provide information  about  the physiological condition of the
                                   animal. They can also detect general stress.

                                   Cytogenetics. Cytogenetics examines the relationship between
                                   changes in the chromosomal structure and pathological condi-
                                   tions.  These changes  can be linked to exposure to specific
                                   pollutants.

                                   Histopathology. Finfish disease can be exhibited through struc-
                                   tural change in tissues or organs during the course of an animal's
                                   exposure to pollutants. Tissue and organ abnormalities  are ob-
                                   served using standard  light  microscopy techniques.  Although
                                   these studies are more expensive, they can detect specific lesions
                                   that develop shortly after pollutant exposure, and long before
                                   gross abnormalities develop.

                                   Egg and  larval development and viability. Eggs and larvae are
                                   sensitive stages in the life cycle of fish Problems with egg or larval
                                   development, such as death or deformity, indicate an ecological
                                   effect that may be due to toxic contamination
                                    Estuary program managers should establish baseline and/or con-
                                    trol  data  for  the  species  and  indicator  methods  under
                                    consideration. Where historical data are inadequate, a reference
                                    area should be established NOAA's Status and Trends Program
                                    has already set up reference areas in or near most of the estuaries
                                    in the National Estuary Program Reference areas, which should
                                    be representative of the entire estuary under study, should be rela-
                                    tively free  from toxic effects. If such an area cannot  be found,
                                    estuary program managers should look for nearby areas with
                                    comparable hydrographic and faunal conditions.

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                                                                 HowtoUseFinfish
                                                                 Indicators in an
                                                                 Estuary Program
                                                                 Years One and Two
During the characterization phase, a preliminary list of priority
problems should be proposed. If there is a decrease in the abun-
dance of fish, a high incidence of diseased  fish, or a potential
threat to human health due to toxins in fish, the following steps are
warranted.

  • Use the low-level suite of indicators; and
  • Synthesize historical data on the abundance of fish, the
    amount and type of tissue residues, and the incidence of
    disease.

At the same time, collect and analyze data on toxic contamination,
sources,  and pollutant loads. If the analysis shows a correlation
between  toxic contamination and changes in  fish, the  program
may choose to:

  • Conduct field sampling to define further the nature and
    extent of the problem;
  • Conduct laboratory toxicity studies to identify the pollutants
    of most concern; and

  • Identify any probable current sources of those pollutants and
    reduce current loadings.


Furthermore,  if toxic  contamination  is the   cause,  follow-up
activities  should be conducted. The program should identify pris-
tine reference areas and summarize all available data on these
areas.
After the contaminant problem has been characterized and neces-
sary critical information Identified, a focused monitoring program
should be designed to assess  correlations between specific
toxicants, or groups of toxicants, and the effects on fish. Indicators
from the high-level suites should be  used during this phase. To
design the monitoring  program,  first  select the  appropriate
species. Follow the guidelines developed in the workshop

 •  A relatively nonmotile, nonmigratory species should be used.
 •  Commercially or recreationally important species are
    preferable.

 •  Species for which baseline data are available are preferable.
 •  Provisions for making an archive of tissue samples for future
    use in assaying additional indicators should be included.
                                                                 Vears Three and Four

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After Year Two
                      Then  consider  which  pollutants  are of  concern.  Determine
                      whether species-specific methods, scientific expertise, laboratory
                      facilities, and  background data are  available. Be sure costs are
                      reasonable. Technical staff and  STAC members should consult
                      and become  familiar with  the entire  workshop proceedings. A
                      summary report contains detailed information on the utility of the
                      various indicator methods.
                      After an activity has begun, implement the monitoring plan.
                      Analyze and synthesize monitoring data, comparing new data with
                      historical data  from the characterization report. Review and
                      evaluate the data periodically to determine whether there has been
                      any improvement in estuarine conditions. Management strategies
                      may have to be redirected or supplemented to achieve a system
                      response.

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                                                        Appendix D
       Summary of the Guidance  Manual for
                       Health Risk Assessment for
                       Consumption of Chemically
               Contaminated Fish and  Shellfish
     This appendix  of the  Estuary Program Primer
     provides guidance for understanding the health risk
     assessment process for seafood consumption. The
     primer, which describes the National Estuary Pro-
     gram's origins, statutory provisions, and approach,
     is designed for EPA's programs and regional offices,
     coastal states,  and other interested parties. For
     more information, contact the EPA regional office.
One of the National Estuary Program's goals is to protect human
health by helping state and local agencies identify the potential
risks of eating aquatic organisms from chemically contaminated
areas. This goal will be met, in part, by developing information on
the relative health risks associated with consumption of fish and
shellfish from a number  of  contaminated estuarine  locations
throughout the United States. A systematic risk assessment pro-
cedure to  estimate  health  risks,  with  clear statements of
assumptions and uncertainties, will be used.

This appendix summarizes a guidance manual that the National
Estuary Program has developed. The manual facilitates stand-
ardization of procedures used to assess the human health risks of
ingesting chemically contaminated fish and shellfish. As of 1987,
the manual  constitutes technical guidance under the National
Estuary Program. It will probably be  issued in 1988 as final EPA
guidance applicable to all  freshwater, estuarine, and marine fish
and shellfish.
                                                 The Guidance
                                                 Manual: An Overview

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    Contents of the
Guidance Manual
        What Is Risk
      Assessment?
                               The risk analysis  process consists of two distinct phases,   risk
                               assessment and risk management Risk assessment involves esti-
                               mating the scientific probability that an adverse health effect will
                               result from exposure to a toxic agent. Risk management entails
                               interpreting  risk assessment results-scientific results-to formu-
                               late public policy. The National Estuary Program manual provides
                               technical guidance on risk assessment procedures; risk manage-
                               ment approaches, which involve policy decisions, are only briefly
                               discussed. Selecting policy alternatives is left to state and  local
                               regulatory authorities  Public  policy decisions  based  on  risk
                               management could be any of the following:

                                  • Identifying locations as high-priority areas for
                                   environmental cleanup;

                                  • Issuing public fish consumption advisories for certain
                                   areas; and

                                  . Banning fishing in certain areas
                               The National Estuary Program health risk assessment guidance
                               manual provides the following information:

                                 • A description of the risk assessment procedure for
                                   chemically contaminated fish and shellfish;

                                 . Guidance on presenting and interpreting risk assessment
                                   results,

                                 . A summary of assumptions and uncertainties of the
                                   recommended procedure for risk assessment; and
                                 . An explanation of the dose-response values that are
                                   available for individual chemicals, and of information
                                   sources for updating these values
                               The document does not provide guidance on the risk manage-
                               ment issue of which level of risk is small enough to be acceptable,
                               given counterbalancing economic factors like consumer prefer-
                               ence or economic  impacts on recreational and commercial
                               fisheries. State or local regulatory authorities will make case-by-
                               case judgments concerning restricting sportsfishing or issuing
                               informational health advisories even when fishing  is not legally
                               prohibited or limited.
                               Risk assessments are limited by rudimentary scientific knowledge
                               of the effects of toxic chemicals on humans. Most of the present
                               information is developed by interpreting results of laboratory tests
                               on experimental animals like rats, mice, and primates for applica-
                               tion  to  humans.  Although  this  extrapolation  carries  many
                               uncertainties, estimates of health risk can be used  to formulate
                               decisions about actions to reduce risk

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 Many  investigators  and  state and local  regulatory agencies
 evaluate the  significance  of  toxic contamination  in fish  and
 shellfish relative to human health concerns simply by comparing
 tissue  concentrations of selected chemicals to Action Levels or
 tolerances established  by the Food and  Drug  Administration
 (FDA). ( An Action Level is a restriction on  chemical contamina-
 tion. Foodstuffs with concentrations of a chemical exceeding the
 Action Level are required by federal law to be confiscated and
 destroyed.) Action Levels do not provide  a sufficient basis for all
 local risk assessments because they are available only for chemi-
 cals likely to be at levels of concern to commercial fisheries on a
 national basis. They do not, therefore, include some chemicals
 highly  suspected of causing cancer or other adverse effects that
 might  be of concern in some local areas due  to  higher-than-
 average local fish consumption and high, localized contamination
 levels.
     Action Levels are national protective levels set by
       FDA. Tolerance levels indicate the ability of an
           organism to fend off an adverse effect.
FDA is authorized to develop Action  Levels or tolerances  for
specific localities if it is in the national  interest. Tolerances have
legal enforcement status, whereas Action Levels have less formal
regulatory limits.  To date, however, all Action Levels and toler-
ances have been developed to be protective on a national basis,
rather than regionally or locally.

The procedure for determining these  national protective levels
involves assessing the health risks to the average national con-
sumer of a foodstuff. It presumes the consumer eats foods from a
typical "national market basket," and weighs the resulting average
national health risks against the likely national  economic impacts
of setting particular levels as Action Levels or tolerances. There-
fore, FDA has stated that Action Levels and tolerances are not
intended to  protect local consumers  of fish  and shellfish,  like
sports-fishermen, who may eat more of a given fish than the
average national consumer.
                     Risk Assessment
        Estimation, using best available  scientific methods,
        of the probable health risks of a given activity.

                     Risk Management
        The use of regulatory tools to protect against levels
        of risk deemed unacceptable based on risk assess-
        ment and socioeconomic considerations.
FDA has the lead responsibility for managing risks related to con-
sumption of foods distributed in interstate commerce. For some
chemicals in foods,  EPA assists FDA  in its  risk management
responsibilities by helping conduct the technical risk assessments

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  What Is Risk
Management?
                        that are the starting point of risk management. FDA then incor-
                        porates economic considerations and develops Action Levels and
                        tolerances. Foods  not distributed through interstate commerce
                        are primarily a state responsibility, not FDA's. Previously, proce-
                        dures for assessing risks from the consumption of contaminated
                        fish and shellfish have not been standardized among agencies -
                        or sometimes, even among programs within a single agency. In
                        addition, risk assessment procedures for other problems, such as
                        contamination of drinking water, have been better developed than
                        those for consumption of contaminated aquatic organisms. The
                        1987 National Estuary Program guidance manual explains how to
                        apply general  EPA  risk assessment   policies to the particular
                        "exposure  route" (mechanism of human exposure) of eating fish
                        and shellfish.

                        The  EPA risk assessment process  is  based on estimating the
                         highest probability, given uncertain technical information, of risks
                        to  humans. The process uses a  combination of empirical data
                         (observational data)  on  the long-term, chronic effects of toxic
                         chemicals, and models for extrapolating from high doses to low
                         doses and from animals to humans. In most cases, empirical data
                         are available only for animal test species. This is primarily because
                         it is hard to obtain long-term (a generation or lifetime)  observa-
                         tions of  human health effects like cancer, and human data are
                         only rarely available, in  cases where accidental  exposures have
                         occurred.
                         Risk management is the application of the results of risk assess-
                         ment by regulatory agencies  to  formulate public policy. For
                         example, regulatory agencies may use the results of risk assess-
                         ment studies  to  develop public health advisories  to limit
                         consumption of particular fish species where contaminant levets
                         are relatively low, or to ban such consumption where levels are
                         higher. In general, the process and outcomes of risk management
                         are case-specific because technical, socioeconomic, and political
                         issues must be considered, and these factors are case-specific.
                         Risk management requires policy makers at federal, state, and
                         local levels to balance these public concerns.

                         In the National Estuary Program and other EPA or state programs
                         for fresh, estuarine or marine waters,  the results of health risk
                         assessment for fish or shellfish consumption generally may be
                         used in risk management to'

                            . Identify problem areas, problem pollutants, and problem
                              fish or shellfish species (and problem weight or length
                              classes within species, if relevant),
                            . Develop guidelines and criteria for contaminant
                              concentrations that would be used to develop fish and
                              shellfish consumption advisories in cooperation with FDA
                              and state governments; and
                            • Provide public information in cooperation with FDA or state
                              governments.

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Risk management is important in areas other than public policy
making. It also provides the public with information on which to
base individual decisions regarding where to harvest aquatic food
organisms, which species to harvest, and how much to consume.
In other words, where to fish, what to fish, and whether to eat what
one catches.
The guidance manual discusses the four major components of the
risk assessment process:  hazard identification, dose-response
assessment, exposure assessment, and risk characterization.
Hazard  identification involves defining the lexicological hazards
(toxicity profiles) posed by each chemical contaminant. Toxicity
profiles  are  based on each  chemical's  physical, chemical,  and
metabolic properties, and on lexicological  effects (also called
"dose-response effects"). Noncarcinogenic  effects  (that is, all
harmful  effects other than causation of cancer, including birth
defects) are summarized in the toxicity profile for each chemical of
concern. The  guidance manual also describes the "weight-of-
evidence" approach used by  EPA to classify chemicals according
to their carcinogenic (cancer-causing) potential.
Dose-response assessment is one factor in hazard identification.
Data on the relationship between the contaminant dose and the
observed "response" (effect on the  test organism) are used to
determine the lexicological  potency of a substance. For car-
cinogens, there is presumably a finite risk of cancer, even at low
doses. For noncarcinogens,  chemicals that induce effects other
than cancer, such as nervous system damage, liver effects, skin
disorders, and birth defects, there is  usually a dose below which
adverse biological  effects are not observed.  This  is called the
"no-observed-adverse-effects level" or  NOAEL.  The  EPA  risk
assessment approach is based on the use of dose-response data
from epidemiological (human disease) studies or from bioassays
of the animal species that are most appropriate for estimating a
response  in humans. Lacking this  information, a measure of
toxicological polency is derived from the dose-response relation-
ship for the most sensitive species tested (usually a laboratory
strain of rats or mice). Results of laboratory experiments are then
extrapolated to humans.

A standardized set of dose-response data then takes into account
all the appropriate laboratory animal and epidemiological studies
available for each  of approximately 200 chemicals provided  by
EPA in a computerized data base. The data base is called the Inte-
grated Risk Information System (IRIS,  EPA 1987).  Periodically
updated versions of the IRIS data base are also available in docu-
ment format from EPA or from the National Technical Information
                                                                Components of the
                                                                Risk Assessment
                                                                Process
                                                                Hazard Identification
                                                                Dose-Response
                                                                Assessment

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                              Service.  Data  on new chemicals are continually added as they
                              become available.
Exposure Assessment
                              Exposure assessment is the process of determining what human
                              populations are exposed to chemicals of concern; the pathways
                              by which they are exposed, and the magnitude, frequency, and
                              duration of the exposure. An  exposure assessment for con-
                              taminated fish and shellfish involves-

                                 • Analysis of tissue concentrations of contaminants in
                                   aquatic organisms;
                                 • Analysis of the exposed human population, including
                                   fisheries harvest activities, rates of consumption of fish and
                                   shellfish, diet  composition, and  other population-related
                                   factors; and

                                 . Estimation of the ingested dose of each food species by
                                   subgroup within the exposed population (for example, age
                                   groups, ethnic groups, and fishermen versus
                                   nonfishermen) and by geographic location.

                              This analysis of a subgroup's overall exposure is called "integrated
                              exposure analysis"

                              Tissue Concentration Analysis. Studies to determine concentra-
                              tions of contaminants in tissues of aquatic biota must be designed
                              carefully. Features to consider include study objectives, species of
                              concern, sampling locations, and sampling times Examples of the
                              relationship between possible objectives and various sampling
                              strategies are provided in the guidance manual. The manual also
                               provides guidance on selecting species for the study and on per-
                              forming statistical analyses of the resulting data.

                               Exposed Population Analysis. The analysis of exposed popula-
                              tions Includes four steps

                                  .  Identify the potentially exposed population by fishery
                                    harvest area,

                                  .  Describe the demographic and aquatic harvesting activities
                                    of the population;
                                  .  Characterize catch and consumption patterns, and
                                  •  Estimate average consumption rates
                              The first three  steps typically involve  conducting surveys of the
                               potentially exposed population. The guidance manual discusses
                               survey methods,  data analyses, and data reporting formats. The
                               summary  exposure variable for use  in subsequent steps of risk
                               assessment is the average consumption rate. The manual pro-
                               vides  guidance for calculating average  consumption rates for
                               each harvested species and, if data are available, for each seg-
                               ment within the human population

                               The manual also shows how to us>e alternative consumption rams
                               derived by other investigators. Decision  makers in each state or
                               locality may choose whether to collect site- specific data on human
                               consumption patterns, or to use typical values derived  from other

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studies. Individuals can also be given the opportunity to determine
their own personal consumption patterns if risk assessment site
results are  presented on the  basis of "risk per meal of fish per
week" or a similar approach.

Integrated  Exposure Analysis. The integrated exposure analysis
results in an estimate of ingested dose by species. The ingested
dose is calculated for specific segments of the human population
(for example, a certain age group along a certain stretch of river).

For a given segment of the exposed population, the ingested dose
is calculated as shown:
      Ingested dose = concentration of a chemical in the
                      edible portion of an organism  x
                      a number representing the relative
                      amount of chemical absorbed by the
                      digestive system  -f   by the
                      average body weight of all in-
                      dividuals in the population segment.
In the risk characterization stage, the preceding steps are brought
together to estimate the probability and extent of adverse effects
associated with consumption  of contaminated  fish or shellfish
from a  given water  body.  Numerical estimates of  risk can be
presented on an individual basis. Risk to an individual is expressed
as a probability (for example, a one in 10,000 increased lifetime
chance of getting cancer or other effects). Risk to a population is
expressed as the excess number of cancers or other adverse ef-
fects produced  within the specific population over one generation.

The results of risk assessment may be presented In both tabular
and graphic format.  All risk estimates should be  interpreted as
plausibte-upper-limit values  for the stated assumptions and expo-
sure conditions, in keeping  with EPA's national guidelines for risk
assessment (EPA 1986). Risk estimates for a  given  area  and
aquatic food species vary with consumption rates, and consump-
tion  rates  vary greatly  among individuals.  Therefore, graphs
showing plausible-upper-limit risks versus consumption rates are
recommended as the primary means of presenting results. Using
the tables to compare the pattern shown on the graphs with per-
sonal consumption rates of various fish and shellfish, consumers
can determine any extra risk to which they might be exposed.

Risk assessment  results should include a  summary of assump-
tions  and an uncertainty analysis. The summary should note
general assumptions inherent in all health risk assessments,  and
specific assumptions adopted for the risk analysis in question.

By using EPA's 1986 policy for risk assessments and estimating
the plausible-upper-limit to risk, it is highly unlikely that risk will be
underestimated. The "upper bound estimate" of the risk is not like-
ly to be exceeded. The actual risk is likely to be below this level,
and may'be close to zero in some instances. Therefore, the esti-
mate  provides  a  consistent basis for  relative risk comparisons
                                                                  Risk Characterization

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References
                     and is a very  conservative (that  is, a "protective") approach to
                     determining whether there are any significant public health risks
                     posed by specific chemicals' contamination of fish or shellfish in a
                     given area. In  instances of contamination by multiple chemicals,
                     EPA's 1986 guidance recommends that the risk estimates from the
                     individual chemicals be added together to obtain the overall risk
                     assessment. This additive approach is neither conservative nor
                     non-conservative because in a few instances effects could cancel
                     one another out, while in others, effects could enhance one
                     another. But the overall risk assessment will remain conservative
                     because each  of the underlying individual risk estimates was con-
                     servative.
                     United States Environmental  Program  Agreement  1987. Draft
                         guidance manual  for health  risk assessment of chemically
                         contaminated  fish and shellfish.  Prepared  for  U.S. EPA,
                         Office of Marine and Estuarine Protection, Washington, DC,
                         by Battelle Memorial Institute, Duxbury, MA, and PTl Environ-
                         mental Services, Seattle, WA.

                     U.S.  Environmental Protection Agency.  1986.  Guidelines  for
                         health risk assessment, Parts II-VI. U.S. EPA,  Washington,
                         DC. Federal Register, Vol. 51,  No. 185.  pp. 33992-34054.

                     U.S.  Environmental Protection Agency.  1987.  Integrated  Risk
                         Information System Supportive Documentation, Volumes I
                         and  II.   EPA  160018-861032a,  March  1987.  U.S.  EPA,
                         Washington, DC.

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