February 10, 1995

EPA-SAB-EPEC-LTR-95-002

The Honorable Carol A. Browner
Administrator
US Environmental Protection Agency
401M Street, S.W.
Washington, DC 20460

       RE:   SAB Review of the Environmental Monitoring and Assessment Program
             Landscape Component

Dear Ms. Browner

       In its 1988 report Future Risk (SAB-EC-88-040) the Science Advisory Board
recommended increased Agency attention to ecological matters, calling for a program to
determine and analyze the status and trends of the nation's ecosystems. The Agency responded by
initiating the Environmental Monitoring and Assessment Program (EMAP), which has grown to
become the largest program currently conducted by EPA's Office of Research and Development
(ORD).

       The EMAP activity  has undergone considerable peer involvement and peer review.
Specifically, the EPEC has  review numerous aspects of the program and issued three reports over
the intervening years. In addition, the National Research Council has provided reviews of the
program which criticize some of its on-going activities1.

       In 1993 the Agency asked the Ecological Processes and Effects Committee (EPEC) to
review the EMAP-Landscapes (EMAP-L, which analyzes  and interprets the landscapes) and
EMAP-Landscapes Characterization (EMAP-LC, which generates information about land cover)
programs. These programs are designed to  incorporate the emerging field of
       1 There have been three NRC reports on EMAP: (1) A Review of EPA's EMAP, An Interim Report, 1992; (2)
A Review of EPA's EMAP: Forests and Estuaries, 1994; and (3) Review of EPA's EMAP: Surface Waters, 1994.

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landscape ecology into the fabric of the EMAP itself. Presentations were made by the key people
on the interagency team that developed the landscape program research plan, Bob O'Neill of Oak
Ridge national Laboratory, Kurt Riitter of the Tennessee Valley Authority, Jim Wickham of the
Desert Research Institute, and Bruce Jones, EMSL-LV, EPA. The EMAP Subcommittee of
EPEC reviewed the issue in a public meeting on July 19-20, 1994 at the Ramada Hotel Old Town
in Alexandria, VA. This letter provides comments from the Subcommittee related to the
questions in the charge (attached).

General Comments

       EMAP-LC and EMAP-L programs have made timely and remarkable accomplishments in
the last two years. Extremely noteworthy is the development of the Landsat Thematic Mapping
(TM) data base for the entire country and the identification and evaluation of indicators of
landscape conditions. It is evident that these accomplishments were due to the competency and
dedication of the
members of the EMAP-LC and EMAP-L team and the leveraging of EMAP resources with other
Federal Agencies.

       The EMAP Subcommittee considers the Landscape components of EMAP to be critical to
accomplishing EMAP goals and objectives. It is evident to the Subcommittee that this aspect of
EMAP currently receives greater support and emphasis in EMAP than it received in the earlier
years of EMAP.  The Subcommittee encourages continued support for EMAP-landscape and
EMAP-landscape characterization activities since they are essential to identify the extent and
condition of ecological resources and can play a critical role in integrating across the landscape
status and trends in the resources groups (e.g., surface water, forest, agroecosystems, estuaries,
and arid lands.) Priorities should be established in the research plan for this integration.

       There is confusion between the terms "EMAP-landscape characterization" and
"EMAP-landscapes". EMAP-L is a component of EMAP that is developing new methodologies
for analyzing landscape features through the advancement of landscape ecology  and EMAP-LC is
the component of EMAP that is facilitating acquisition of TM data to characterize the landscapes
of the nation in concert with other federal agencies. To reduce confusion and to employ
parallelism in terminology, we suggest "EMAP-landscapes" be replaced with either
"EMAP-landscape analysis" or "EMAP-landscape interpretation".

       EMAP management needs to recognize and support the important leadership role that
EMAP-L and EMAP-LC have for all of EMAP.  Even though the landscape work is only

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about 8% of the full EMAP 1994 budget, the results from EMAP-L and LC and assessments are
crucial to the success of EMAP; however, their linkage to the Resource Groups should be
formalized. Therefore, it is essential to link the landscape research even more tightly and formally
to address assessment questions.  The EMAP-L/LC team and the Assesment Group should
develop a clear explanation of the assessment approach to facilitate linkages for integration and
assessment among the EMAP Resource Groups and other monitoring programs within the
Agency (e.g., Near Coastal Resource Group and the National Estuary Program).

Responses to the Charge Questions

Charge Question 1: Has a sufficient case been made (by EMAP & EMAP-Landscapes) for the
"need for landscape monitoring and assessment?

       Yes. Landscape monitoring and assessment is a critically important component of EMAP.
To be a success, EMAP must provide status and trend  and resource stress information at the
landscape scale.

Charge Question 2: Is the conceptual and theoretical foundation for EMAP-L sound?

       Yes. The conceptual and theoretical foundation for EMAP-L is appropriately based on
the science of landscape ecology. The constraint, however, is that the field landscape ecology is
in an early stage of development. Indeed, the research and grant support provided by EMAP-L to
the development of basic landscape ecology concepts and theory is  a significant portion of all
funding for this very important research area.  It was noted that the potential exists in the
scientific community to expand that level  of effort many fold if additional resources were
provided.  The Subcommittee
believes this development of the conceptual underpinnings of landscape indicators, including what
they mean ecologically across scales and societal boundaries, is so essential to the long-term
success of landscape-level components of EMAP that significantly increased resources are
necessary for this research.

Charge Question 3: Does the EMAP-L approach adequately address the EMAP objectives?

       Yes. The objectives outlined in the Landscape Monitoring and Assessment Research Plan
parallel the objectives of EMAP in terms of estimating status and trends in indicators of ecological
condition.  The EMAP-L component explicitly analyzes spatial configurational characteristics
among ecological resources.

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Charge Question 4:  Is the proposed monitoring and assessment approach realistic?

       The foundation of EMAP-L's approach to monitor status and trends in the condition of
landscapes is remotely sensed TM data analyzed every 5 to 10 years.  The Subcommittee feels
that this approach to monitoring is realistic and scientifically sound and can be effectively
implemented. Information presented to the Subcommittee on how the condition of landscapes
will be evaluated (i.e., assessment) was in the preliminary stages of development.  The approaches
(i.e., indicators) being explored appeared to hold promise. However, a clear articulation of the
EMAP-L's assessment approach needs to be developed before it can be
evaluated for scientific validity or realism.  The EMAP-L/LC team needs to develop a clear
explanation of the emerging assessment approach. This will be of value not only to EMAP-L but
to all aspects of EMAP since scientifically sound assessment approaches are critical to meeting
EMAP goals.

Charge Question 5:  Has EMAP-L involved basic science researchers in the conceptualization of
its approaches?

       Yes, within the constraints of its resources, EMAP-L has done an excellent job of
involving basic science researchers in the conceptualization of its approaches. Bob O'Neill from
Oak Ridge National Laboratory, a primary participant in EMAP-L, is one of the founders of
modern landscape ecology.  A number of other landscape ecologists have also been involved as
primary participants and sources of technical input. Approximately 95% of the EMAP-L budget
has gone to researchers outside of EPA, an impressive level of extramural involvement. EMAP-L
has actively sought input from basic researchers on its  approaches. For example, it was reported
that ideas from surface water scientists expanded the thinking about landscape level indicators.
Additional involvement with landscape-level researchers in other scientific disciplines, both within
and outside of EPA, would be expected to provide comparable benefits.

Charge Question 6:  Is the linkage between EMAP-Landscapes and EMAP-Landscape
Characterization adequate to accomplish the goals of both programs?

       The linkage between EMAP-L and EMAP-LC  appears to be very well developed through
the close cooperation of key personnel in each unit. However, there needs to be a formal linkage
so that it is not just ad hoc or dependent on the specific individuals involved.

Charge Question 7:  Does the EMAP-L approach provide a framework for integrating EMAP
Resource Group data across scales? Will the approach enhance the ability of EMAP to do
cross-ecological resource assessments?

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       The EMAP-L efforts hold tremendous promise for providing EPA with tools and a
context for cross-ecological resource assessment. We anticipate that this landscape level
information will allow the integration of resource group data in a way that supports assessment
and decision-making at smaller scales by placing the Resource Group data in a broader
environmental (ecological system) context. The scientific framework is rapidly developing in
directions that will serve EPA needs. However, the organizational responsibilities and process for
this integration within EMAP does not appear to be adequately developed.  The Subcommittee is
concerned that by default the EMAP-L and EMAP-LC components will become overly burdened
by integration and assessment tasks when their primary emphasis should be on database
development and the development and testing of landscape level methodologies for meeting
EMAP's overall goals.

       Efforts to date on integrating with Resource Groups (e.g., surface water, forests, and
agro-ecosystems) have been fruitful, but have been conducted on an ad hoc basis.  Formal efforts
to link Resource Groups with the EMAP-L efforts must be undertaken. The EMAP Assessment
group may be able to play a role as a facilitator of EMAP-L interaction with other Resource
Groups in order to develop and implement tools that allow cross-ecological resource assessments.
The Subcommittee recommends that the EMAP assessment group work closely with the
EMAP-LC and EMAP-L groups to develop clearly defined goals and linkages between landscape
level data and how it will be integrated with the data generated by the resource groups.

Charge Question 8:  Does the EMAP-L approach increase the value of EMAP data in conducting
ecological risk assessments?

       The EMAP-L approach is consistent with the approach of the risk assessment framework
yet the linkages have not been explicitly laid  out. Now that the EMAP-L approach has been
defined, it would be appropriate for the researchers to articulate the relation of the landscape
approach to both the EMAP data from other resource  groups and how  all of this information
relates to the ecorisk framework. The relationship between the EMAP-L approach and the
Framework for Ecological Risk Assessment (EPA/630/R-92/001, 1992) is not explicitly made in
the Landscape Monitoring and Assessment Research Plan (1994) nor in the presentations made to
the Committee at the review.

Charge Question 9:  Has EMAP-L worked to assure that results of efforts, to date, are reported
to the landscape ecology community?

       EMAP-L has reported research results via peer-reviewed publication in Landscape
Ecology and other appropriate journals. Publication in peer-reviewed literature is critical to

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the success of EMAP and is strongly encouraged. In addition, related publications should be
serially numbered to facilitate reference and highlight the magnitude of the contributions of this
program.

Charge Question 10:  Has EMAP-L identified key technical issues that need resolution to
implement the program?

       EMAP-L has identified several key technical issues which must be resolved to implement
the program.  Five were enumerated in the presentation: (1) refinement of societal
values/conceptual models, (2) landscape units and scales, (3) sampling designs, (4) landscape
indicator development,  and (5) synergism of different remote sensing data to evaluate landscape
status and change.  The Subcommittee concurs that these are the key technical issues.

Charge Question 11:  Are the proposed research and development activities realistic and
appropriate to resolve the major technical issues?

       The proposed research and development activities to address the identified technical issues
appear appropriate. However, there was no stated prioritization of those technical issues in the
research plan, which was viewed by the committees as needed, given the limited available
resources. The effort expended appeared to be greatest for technical issues 4 (Landscape
indicator development) and issue 5 (synergism of remote sensing  data) and substantial progress
has been made.  Work on issue 3, sampling design, should proceed concurrently with indicator
development, since the  two are interrelated.  In particular, sample design issues related to
integration/assessment with individual ecological resources (e.g. streams, forests, estuaries,
agricultural lands) should be addressed early in the process, so that the landscape indicators
chosen will be meaningful in terms of the ecological endpoints being measures by these resource
groups.

Charge Question 12:  Is the approach and organization of the MRLC [Multi-Resolution
Landscape Characterization] a reasonable framework to meet our objectives?

       The Subcommittee was impressed by EPA's leadership in  coordinating the MRLC.  It is
cost-saving and time-saving and supportive of research to have a  coordinated effort of data
acquisition and processing. The MRLC approach and framework seem appropriate to meet the
goal of providing a current baseline of global multi-scale environmental characteristics, and
mechanisms for monitoring, targeting and assessing environmental changes.  Denice Shaw is to be
commended for her success in pulling the group together.

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       However, there are some issues that need to be dealt with in order to continue this
successful record. EMAP needs to provide more personnel support to EMAP-LC so that
ongoing activities can be fully supported while future activities are identified and developed.
There are, at least, four ongoing activities that
need some focused support:

(1) Quality assurance of the data - The EMAP-LC group recognizes the importance of
well-documented, quality-assured data and has recommended steps to develop and implement
information management efforts. Additional funds should be provided to develop and implement
a quality control program, to develop data qualifiers related to precision, accuracy, and validation
of land cover data.

(2) Validation - We encourage EMAP-LC to take a key role in this issue and to recognize the
need for personnel with training in this area.

(3) Communication with the research community - although the researchers have done a good job
of publishing the research results, we also encourage the dissemination of information about the
availability of the MRLC data.  This communication could be  achieved by articles in the bulletins
of scientific societies as well as posting on the INTERNET.

(4) Classification- We endorse the proposed interface with a committee of the Ecological Society
of America to consider classification issues. However, EMAP-LC should recognize that
significant time and effort may be required, so specific objectives should be developed to focus
the discussions.

       In  summary, we were impressed by the amount of work accomplished, yet we are
concerned that there are too few people for too many tasks. There is also a concern that
EMAP-LC is susceptible to the loss  of one key individual. We support efforts to formalize the
work to date and recommend that ORD develop a strategic plan for the EMAP-Landscape
Characterization program.

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       We have appreciated the opportunity to review this component of EMAP and we look
forward to receiving a formal response to these comments. Further, we would like to know how
the Agency will respond to recent comments on the EMAP resource groups from the NRC.

                                 Sincerely,
                                 Dr. Genevieve M. Matanoski, Chair
                                 Executive Committee
                                 Science Advisory Board
                                 Dr. Mark A. Harwell, Chair
                                 Ecological Processes and
                                 Effects Committee
                                 Dr. Kenneth L. Dickson, Chair
                                 EMAP Subcommittee

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                   U.S. ENVIRONMENTAL PROTECTION AGENCY
                            SCIENCE ADVISORY BOARD
               ECOLOGICAL PROCESSES AND EFFECTS COMMITTEE
                              EMAP SUBCOMMITTEE

                                   July 19-20, 1994

                                      ROSTER
CHAIR
      Dr. Kenneth L. Dickson, Director, Institute of Applied Sciences,   University of North
      Texas, Denton, Texas

MEMBERS/CONSULTANTS

      Dr. Harry L. Boston, III, Environmental Restoration Program, Oak Ridge National
      Laboratory, Oak Ridge, Tennessee

      Dr. Virginia Dale, Environmental Sciences Division, Oak Ridge National Laboratory, Oak
      Ridge, Tennessee

      Dr. Mark A. Harwell, Rosenstiel School of Marine and Atmospheric Science, University
      of Miami, Miami, Florida

      Dr. Carol A. Johnston, Natural Resources Research Institute, University of Minnesota,
      Duluth, Minnesota

      Dr. Frederic K. Pfaender, Director, Carolina Federation for Environmental Studies,
      University of North Carolina, Chapel Hill, North Carolina

      Dr. William H. Smith, Professor of Forest Biology, School of Forestry and Environmental
      Studies, Yale University, New Haven, Connecticut

SCIENCE ADVISORY BOARD STAFF
      Dr. Edward S. Bender, Designated Federal Official, US EPA, Science Advisory Board
      (1400F), 401 M Street, SW, Washington, DC 20460

      Ms. Stephanie Sanzone, Designated Federal Official, US EPA, Science Advisory Board
      (1400F), 401 M Street, SW, Washington, DC 20460

      Ms. Mary Winston, Staff Secretary, US EPA, Science Advisory Board (1400F), 401 M
      Street, SW, Washington, DC 20460

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                     Charge for the SAB Review of EMAP Landscapes

    EMAP-Landscapes (EMAP-L) proposes to monitor and assess status and trends in
landscape condition nationally using landscape indicators.

       1. Has a sufficient case been made (by EMAP & EMAP-Landscapes) for the "need for
       landscape monitoring and assessment?
   2. Is the conceptual and theoretical foundation for EMAP-L sound?
   3. Does the EMAP-L approach adequately address the EMAP objectives?
   4. Is the proposed monitoring and assessment approach realistic?
       5. Has EMAP-L involved basic science researchers in the conceptualization of its
       approaches?
       6. Is the linkage between EMAP-L and EMAP-Landscape Characterization adequate to
       accomplish the goals of both programs?

    EMAP-Landscapes proposes that a national landscape monitoring and assessment program
will bring several benefits to EMAP, as well as the environmental community in general.

       7. Does the EMAP-L approach provide a framework for integrating EMAP Resource
       Group data across scales?  Will the approach enhance the ability of EMAP to do
       cross-ecological resource assessments?
       8. Does the EMAP-L approach increase the value of EMAP data in conducting ecological
       risk assessments?
       9. Has EMAP-L worked to assure that results of efforts, to date, are reported to the
       landscape ecology community?

    EMAP-Landscapes has proposed a series of research projects to resolve key technical issues
that prevent implementation of the program.

       10. Has EMAP-L identified key technical issues that need resolution to implement the
       program?
       11. Are the proposed research and development activities realistic and appropriate to
       resolve the major technical issues?

    The Multi-Resolution Landscape Characteristics Consortium (MRLC) is designed to meet
the collective needs of the four national monitoring programs with regard to providing baseline
land cover data.

       12. Is the approach and organization of the MRLC a reasonable framework to meet our
       objectives?
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