I JSL \ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C, 20460
OFFICE OF
THE ADMINISTRATOR
July 30, 1991 EPA-SAB-EPEC-91-011
The Honorable William Reilly
Administrator
U.S. Environmentml Protection Agency
401 M Street, S.W.
Washington, D.C. 20460 n-
Dear Mr. Reillyt
The Ecological Monitoring Subcommittee of the Ecological
Processes and Effects Committee of the SAB has reviewed of the
Program Plan for the Environmental Monitoring and Assessment
Program (1MAP). The charge to the Subcommittee was to 1} examine
the adequacy of the Program Plan in describing EMAP to the
scientific community and to IPA Program and Regional Offices; 2)
determine if the Program Plan's description of the interface
between EMAP and Risk Characterization is adequate to establish
linkages between the two elements of the ecological risk
assessment paradigm? and 3) evaluate whether or not the overall
EMAP approach outlined in the Program Plan will contribute to
EPA's mission of managing for environmental results.
The Subcommittee recommends that the Program Plan be divided
into two documents. One part should be a short overview
addressed to the general public. The second should be an
expanded version directed to the scientific/technical community.
The draft Program Plan reviewed by the Subcommittee attempted to
address both audiences and by so doing compromised its ability to
meet the needs of either audience, A revision of this document
should not wait until all of our recommendations have been
addressed, but rather EPA should use the Prograra Plan to document
stages in the development of EMAP. It may be useful to issue
additional volumes of the plan periodically to describe changes
that have been made in the program based on the results of the
demonstration and pilot studies and other continuing research and
assessments,
The Subcommittee believes that EMAP can significantly
contribute to the ecological risk assessment paradigm being
developed by the Agency. However, the Program Plan does not
adequately explain how EMAP fits into ecological risk assessment.
Based on the draft Program Plan and the briefings presented
during the review, it is evident that EMAP has the potential to
assist the Agency manage for results. However, the Program Plan
could more effectively communicate EMAP's role and contributions
Printed on Recycled Paper
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to this mission by more clearly describing the goals and
objectives of the program. Examples of the kind of ecological
issues that EMAP can and cannot address should be included in the
Program Plan.
A major concern of the Subcommittee was the lack of
information in the Plan on how the various components of IMAP
will be integrated and how status and trends will be assessed.
Information presented to the Subcommittee during the review
indicated that this aspect of EMAP was still being developed.
The Subcommittee recommends that this component of EMAP be given
a high priority, since it is essential to the success of EMAP.
Based on the review of the Program Plan, the Subcommittee
recommends that the following critical components of EMAP be
earmarked for future review by the SAB;
* Progress with Indicator Selection
* Integration and Assessment Component
* Results of the Demonstration Projects-
particularly Near Coastal and Forest Ecosystems
* Landscape Characterization Approach
The SAB appreciates the opportunity to conduct this
scientific review and looks forward to receiving your response.
Sincerely,
Dr. Raymond LoeTir, Chairman Dr. Kenneth Dickson, Chairman
Science Advisory Board Ecological Processes and
Effects Committee
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CD A U'S* Environmental Washington, DC
tr A Protection Agency EPA~SAB-iP£C-91-Q11
Report of The
Ecological Monitoring
Subcommittee of The
Ecological Processes and
Effects Committee
Evaluation of The
Program Plan
for EMAP
A SCIENCE ADVISORY BOARD REPORT July, 1991
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U.S. ENVIRONMENTAL PROTECTION AGENCY
NOTICE
This report has been written as a part of the activities of
the Science Advisory Board, a public advisory group providing
extramural scientific information and advice to the Administrator
and other officials of the Environmental Protection Agency, The
Board is structured to provide a balanced expert assessment of
scientific matters related to problems facing the Agency. This
report has not been reviewed for approval by the Agency; and,
hence, the contents of this report does not necessarily represent
the views and policies of the Environmental Protection Agency or
other Agencies in Federal Government. Mention of trade names or
commercial products do not constitute a recommendation for use.
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ABSTRACT
This report presents the conclusions and recommendations of
the U.S. Environmental Protection Agency's Science Advisory Board
following a review of EPA's Program Plan and a briefing on
ecological risk characterization for the Environmental Monitoring
and Assessment Program (EMAP). This is the second in a series of
reviews by the SAB of the components of EMAP. The Subcommittee
recommended that EPA revise its Program Plan to clarify the
purpose, goals, and objectives of EMAP and explain how EMAP can
support policy decisions. They recommended that EMAP further
examine its role in risfc assessmentI one which is critical toward
accomplishing Agency goals. The Subcommittee recommended that
IMAP illustrate the integration and assessment portion of its
program using data from the Near-Coastal and Forest pilot
projects and present this analysis to the SAB for review.
KEY WORDS; Environmental Monitoring; Ecosystem assessment;
ecological rislc assessment.
11
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U.S. ENVIRONMENTAL PROTECTION AGENCY
SCIENCE ADVISORY BOARD
ECOLOGICAL PROCESSES AND EFFECTS COMMITTEE
ECOLOGICAL MONITORING SUBCOMMITTEE
ROSTER
CHAIRMAN
Dr. Kenneth Dickscm*
Director
University of North Texas %
Institute of Applied Sciences
P.O. Box 13078
Denton, Texas 76203
VICE-CHAIRMAN
Dr. Stanley Auerbach*
Director
Environmental Sciences Division
Oak Ridge National Laboratory
Oak Ridge, Tennessee 37831
MEMBERS
Dr. Donald F. Boesch
Center for Environmental
and Estuarine Studies System
University of Maryland
P.O. Box 775
Cambridge, Maryland 21615
Dr» Mark. A. Harwell
Rosensteil School of Marine
and Atmospheric Science
University of Miami
4600 Rickenbacker Causeway
Hieni, FL 33149
*Members on the Executive Cowsiittee
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Dr. Robert Huggett*
Professor
Virginia Institute of Marine Science
School of Marine Sciences
College of William and Mary
Gloucester Point, Virginia 23062
(Member Executive Committee)
Dr. Richard Kimerle
Monsanto corporation
800 N. Lindbergh Boulevard
St. Louis, Missouri 63167-5842
Dr. Paul Risser
Provost & Vice President of
Academic Affairs
University of New Mexico
Scholes Hall 108
Albuquerque, New Mexico 87131
CONSULTANTS
Dr. Daniel Goodman
Montana State University
Department of Biology
Louis Hall
Bozeman, Montana 59717
Dr. Allan Hirsch
Director
Washington Office
Midwest Research Corporation
6 Skykline Place, Suite 414
5109 Leesfaurg Pike
Palls Church, Virginia 22041
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Dr. John Neuhold
Department of Wildlife Sciences
College of Natural Resources
Utah State University
Logan, Utah 84322
Dr. William H. Smith
Professor of Forest Biology
School of Forestry
and Environmental Studies
Yale University
370 Prospect Street
New Haven, Connecticut 06511
•>,
Dr. William Winner
Department of General Science
Wenger Hall 355
Oregon state University
Corvallis, Oregon 97331-6505
SCIENCE ADVISORY STAFF
Dr. Edward S. Bender
Biologist & Executive Secretary
U.S. Environmental Protection Agency
Science Advisory Board
401 M Street, SW.
Washington, D.C. 20460
Mrs. Marcy Jolly
Secretary to the Executive Secretary
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TABLE OF CONTENTS
1.0 EXECUTIVE SUMMARY „ » ......... 2
2,O INTRODUCTION .,»....,...,,.„.... 3
2.1 Statement of the Charge ..... 3
2.2 Subcommittee Review Procedures ....... 3
3.0 COMMENTS ON THE EMAP PROGRAM PLAN 4
3,1 General Comments . . ............ 4
3*1.1 Need to Describe Evolving Nature
of EMAP ...... * ......... 4
3.1.2 Target Documents Toward
Specific Audiences . 5
3.1,3 Recognize and Explain Uncertainties . . 6
3.1.4 Eliminate Overstatements and
Inaccuracies ..... .... 7
3.1.5 Establish Performance Standards . . . . ?
3.1.6 EMAP and Policy Issues 7
3.1.7 Indicator Selection Process .8
4.0 RISK ASSESSMENT AND EMAP .....§
5.0 EMAP IMPLEMENTATION .....*......... .10
5.1 Defining Assessment and Integration 10
5.2 Preparation for NEC Review 13
5.3 Landscape Characterization 13
6.0 SUMMARY OF RECOMMENDATIONS ........14
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1.0 EXECUTIVE SUMMARY
The Ecological Monitoring Subcommittee of the Ecological
Processes and Effects Committee of the Science Advisory Board
(SAB) reviewed a Program Plan for the Ecological Monitoring and
Assessment Program (EMAP) and received a briefing on the
relationship between EMAP and activities to develop Ecological
Risk Assessment Guidelines within EPA. The Subcommittee was
asked to: 1) review the adequacy of the Program Plan to describe
the EMAP approach for risk based environmental management; 2}
review the interface between EMAP and Risk Characterization; and
3) assess EMAP's potential to support the Agency's mission of
managing for environmental results.
The Subcommittee found that while the Program Plan had many
useful concepts, it was somewhat confiising because it did not
explain that EMAP is part of an integrated strategy for assessing
risks to natural ecosystems. The Subcommittee recommended that
EMAP revise the plan and divide it into two documents, one
targeted to a general audience and another one with more detailed
information for the scientific community. The plan needs to be
carefully edited to eliminate some of the overstatements and
inaccuracies, to recognize EMAP's role in quantifying the
uncertainty of its own results, and to explain that the program
is evolving based on its own experience. The Subcommittee also
recommended that EMAP carefully articulate and document its
interim goals and establish some criteria for judging its
success. Finally the plan should give more explanation of how
EMAP can be used to address major policy issues that face the
Agency as part of risk reduction.
The Subcommittee believes that EPA's use of ecological risk
assessment is a significant and positive trend for assessing
anthropogenic risks to ecosystems. However, the plan does not
explain how EMAP will fit into the assessment of relative risks
nor does it include this as part of the strategy for selection of
indicators. The Subcommittee recommends that EMAP further
examine how its data can feed into the various Risk Assessment
paradigms being considered by the Risk Assessment Guidelines
development team.
The Subcommittee recommends that EMAP analyze its goals and
objectives with respect to their position along a continuum from
change detection through ecological risk assessment. The
location along this continuum will determine the monitoring
capabilities, methods and research needs of EMAP. The current
plan reflects a mixture of goals; consequently the Subcommittee
cannot currently evaluate how well EMAP can contribute to the
mission of the Agency. The Subcommittee recommends that EMAP use
its data from the Near-Coastal and Forest pilot projects to
illustrate the integration and assessment portion of the program.
The Subcommittee would like to review such analysis in the near
future.
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Overall, while the Subcommittee commends the EMAP for
tackling an important but difficult task, much attention and
thinking needs to be focused on the Program Plan, the linkages
with risk assessment, and the integration and assessment of EMAP
data in order for success to be sure.
2.0 INTRODUCTION
The Ecological Monitoring Subcommittee of the Ecological
Processes and Effects Comiaittee of the Science Advisory Board
(SAB) met on March 18-19, 1991, to review a Program Plan for the
Ecological Monitoring and Assessment Program (EMAP) and to
receive a briefing on the relationship between EMAP and
activities to develop Ecological Risk Assessment Guidelines
within EPA. This was the second review of aspects of the 1MAP
program fay this Subcommittee. Previously the Subcommittee had
reviewed the Indicators document (EPA-SAB-EPEO91-QQ1) . This
review was conducted at the request of the Office of Research and
Development (ORD).
2,1 Statement of the Charge
The Acting Director of EMAP, Dr. Frederick Kuts, requested
that the SAB review the EMAP Program Plan. As part of the
review, the Subcommittee was requested to address the following
questions:
Does the EMAP Program Plan adequately describe the
approach EMAP is pursuing to achieve the Program
objectives and contribute to EPA's risk based approach
to environmental management? Will this Program plan
be useful in describing EMAP to the scientific
community and to EPA Program and Regional Offices?
Has the interface between EMAP and Risk
Characterization been described sufficiently in the
Program Plan so the linkages between these two elements
in the ecological risk assessment paradign are evident?
Based on written and oral presentations, is EMAP moving
in a direction that, following implementation, will
permit it to contribute to the Agency's mission of
managing for results?
2.2 Subcommittee Review Procedures
The Environmental Monitoring Subcommittee (EMS) is a
standing group of the Ecological Processes and Effects eoiaraittee
of the SAB and was established to review critical components of
the EMAP program, including the identification and selection of
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indicators, landscape characterization, and. the analysis and
interpretation of results from the demonstration and pilot
projects. The Subcommittee relies on the results of peer
reviews, which may include some members or consultants to the
Subcommittee, as a source of detailed comments on particular
technical issues. The Subcommittee has also established a
liaison with a committee at the National Research Council that is
also reviewing EMAF over a three year period.
The EMS has established its agenda in response to specific
requests from the Office of Research and Development and through
follow-up to its own questions. The Subcommittee membership is
drawn from the members and consultants of EPEC and supplemented
as appropriate with additional expertise to address particular
scientific issues and questions. ">
3 * 0 COMMENTS ON THE EMAP PROGRAM PIAH
3.1 General Comments
When EMAP was formulated (1988), it was conceived as part of
an integrated strategy to improve EPA's capability for assessing
risks to natural ecological systems from current and emerging
regional-scale environmental pollutants. This strategy had three
major components; an Environmental Monitoring and Assessment
Program (EMAP), that would serve to characterize, classify, and
quantify trends in the status of ecological
resources and pollutant exposure; a Core Ecological Research
Program (CERP), that included EMAP and would also focus on
developing tools to predict ecosystem-level responses to
incremental changes in anthropogenic activities; and an
Ecological RisJc (EcorisJc) Program, that allows monitoring and
research output to be integrated into quantitative estimates of
ecological risk, at all levels of organization. The draft
Program Plan reviewed by the Subcommittee does not explain this
combined strategy which is essential to the establishment of a
final operational design but also will be critical in the future
for the interpretation of IMAP results*
The development of a Program Plan and a long-term
development and implementation strategy should help EMAP to
identify the questions that can be addressed by this program and
to inform potential users and the public about the need to obtain
these data. In addition, EMAP must develop a strategy for
explaining how the data are collected and evaluated and for
reporting the results to users and interested parties.
3.1,1 Need to Describe Evolving Nature of EMAP
The EMAP Program Plan conveys the impression that the
program's design is much more fixed than is actually the case.
The briefings that the Subcommittee received indicated that
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various fundamental elements are still evolving through testing
and pilot scale evaluations. The landscape characterization,
sampling design, and the nominal-suhnotninal concept are examples
of this testing and evolution. The Subcommittee supports this
more flexible approach and believes that the document would have
greater scientific credibility if it identified for each major
program element the questions and uncertainties that have to be
resolved before the program becomes fully operational.
The draft also does not reflect in positive terms that the
EMAP will conduct a five year or more test and development effort
to ensure that the design was appropriate, that the selected
bioindicators were in fact going to be useful and that the data
management, integration and assessment activities will be
effective in meeting both scientific aftid risk management needs,
A concise, clear statement of sampling strategy is needed
for the Program Plan. This statement should include a specific
definition of Tiers 1, 2, 3, and 4. It should explain how
40-hexagon units will be selected and how all resource categories
will be sampled. The Plan should also discuss sampling for Tier
3 and 4.
EMAP consists of a number of interrelated components. To
communicate this complexity, it would be valuable to develop a
flow chart that describes the important parts of the Program Plan
and the interrelations among them.
3.1.2 Target Documents Toward Specific Audiences
The current document tries to do too much for too many
audiences, it is too long and technical for a general audience
and too general for the scientist. The Subcommittee recommends
that the document be rewritten as two documents: 1) one a
general overview of the rationale and framework for the program
addressed to parts of EPA, other agencies, and other interested
parties; 2) the other as a detailed scientific document directed
to the scientific community.
The overview should emphasize the need for EMAP to monitor
ecological variables that are indicative of ecological
organization that might be important to society. For instance,
it could explain what could happen to society if our ecosystems
should fail to serve our environmental needs. It should explain
that EMAP will measure indicators of ecological status that could
be useful signals of long-term regional, national and global
trends that may have an impact on food production and human
welfare.
The overview should also emphasize the importance of
interagency cooperation in implementing the plan giving details
on how EMAP findings will contribute to the missions of other
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agencies, and about the need for other agencies to contribute
data and information to £MAt»» Proa this document, a, brief
overview could be derived for the general public.
The detailed document should specifically set forth the
expectations of the program and the expected deliverable products
along with time lines for the deliverables. The detailed program
plan should outline an approach for attaining products as well as
detailing methods for demonstrating products. The plan should
also show how results will be appraised and evaluated and explain
the iterative nature of the program.
While it may be clear to environmental scientists that
decades of monitoring may be required to detect subtle ecological
changes, the less experienced may expect the same results within
a few years. This could result in loss of confidence and support
for the program.
3.1,3 Recognize and Explain Uncertainties
In its attempt to present a forceful case for EMAP, the
Program Plan does not adequately portray the uncertainty involved
in assessing environmental conditions and trends. The
uncertainty has many components in addition to the usual
statistical sense. Has the ecosystem changed in important ways
that are not adequately reflected in the indicators? How certain
is one of the affects of the observed changes on ecosystem
functions or communities (e.g., Are they beneficial or
detrimental?)? These and other issues deserve honest discussion
in the Program Scope and Integration and Assessment sections of
program plan. Concepts defining uncertainty should be developed
in a style which helps the decision maker evaluate the degree of
emphasis that should be placed on EMAP within the constellation
of environmental research, assessment, and management approaches.
Furthermore, the decision maKer furnished the products of
monitoring and assessment must have some quantification of the
uncertainty involved in the interpretation of results for use in
risk management decisions. Therefore, attention must be given in
the Program Plan for development and implementation of
methodologies that will quantify the uncertainty.
The language of the draft implies that this is a fully
designed effort ready to go on line and to produce results.
Moreover it treats several pilot projects (coastal, Northeastern
forests, wetlands) as if they were already fixed components
rather than clearly indicating that they were part of a
systematic testing effort to determine the appropriateness of the
bioindlcators chosen. It would strengthen the document (at least
from a scientific viewpoint) to indicate that these projects are
part of the preliminary test and evaluation effort that will lead
to definition of the routines needed for environmental
monitoring.
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3.1.4 Eliminate Overstatements and Inaccuracies
The Program Plan should be reviewed for the accuracy of the
biological concepts and facts. Overstated or inaccurate
statements in the Plan can reduce the ultimate acceptance of the
program. For instance on page 35 of the draft, it is stated that
the presence of large indigenous bivalves is a measure of the
habitat's ability to support shellfish. This is not necessarily
true. Over-harvest can diminish stocks below maintenance levels
in some areas while the physical and chemical habitat remains
viable relative to shellfish. Another example can be found on
the same page where it is claimed that chemical contaminants in
sediments can be used as a direct measure of exposure. Again
this is not necessarily true. Sediment-associated contaminants
may not be biologically available.
Another aspect of the report that deserves consideration
involves better justification for some elements in the program.
For instance it is difficult to imagine how the presence of large
indigenous bivalves could be considered more important as an
indicator than plankton populations. It would appear that the
program has drawn this conclusion since the former is included
but plankton is not, yet there is growing evidence that the
coastal planktonic community in some parts of the world is
changing due to anthropogenic factors.
3.1.5 Establish Performance Standards
The Program Plan needs to have a discussion of the criteria
(performance standards) to be used to determine if EMAP is
accomplishing its goals and objectives. How will it be
determined if EMAP is effective? While the Program Plan includes
some discussion of Peer Evaluations and QA/QC efforts, it does
not identify performance standards which can be used to judge the
success of the program. A discussion of interim goals and the
criteria for judging success will increase EMAP's credibility.
3.1.6 EMAP and Policy Issues
The draft does not make a strong linkage between the science
that will be undertaken and its relation to at least some policy
issues. This effort is supposed to be decades in length and
costly (at least by previous standards), It would strengthen the
document if some examples of policy related issues or questions
that EMAP may address could be included. These would serve as
illustrations of the potential uses for the scientific data that
may result from this program. How, for example will this program
relate to the requirements of the new Clean Air Act amendments?
The Act calls for a continuation of NAPAP related studies on the
impact of acid precipitation. Does EMAP have a role here? What
about the assortment of issues dealing with Climate Change? Are
there potential regional versus national questions of policy
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nature for which this program will be able to provide valuable
scientific data and insight? By including such material in the
Introduction it will present a stronger rationale for EM&P In
both in the policy and science communities.
The current description of EMAP has focused on various
aspects of approach and procedure. However, currently the
Program Plan description does not carefully analyze the specific
types or individual questions that can be answered by the
program. A useful illustration of the capabilities of EMAP would
be to present several critical environmental issues and then
analyze just how the issues would be evaluated and answered from
the EMAP design.
%
3.1.7 Indicator Selection Process
The process for selecting indicators for monitoring
environmental change is not stated in a simple, clear fashion.
Although criteria for such indicators are listed, it is not
obvious how the criteria were determined, or why they should
exist. More useful than criteria would be the outline of a
process for selecting these indicators and documenting how they
are quantitatively related to the assessment products that will
be developed by EMAP. The Subcommittee previously made
recommendations that EMAP should clarify the indicator selection
process and standardize the criteria used to evaluate indicators
among ecosystems (EPA-SAB-EP1C-91-QQ1, November, 1990). These
recommendations should also be reflected in the revisions of this
plan.
The Plan must show how indicators will be used to monitor
environmental change and accomplish other programmatic goals.
The use of indicators might build on issues such as those
outlined in the NRG volume, Biologic Markers of Air-Pollution
Stress and Damage in Forests (1989, National Academy Press, 363
p.) .
Natural variability of indicators must be taken into account
in order to determine when environmental change has occurred.
More specifically, the natural variability for the chosen
indicators must be known or measured. Without an estimate of
variability, it is not clear how indicators could be used to
distinguish between changed and unchanged environments. Further,
the variability of indicators chosen for environmental monitoring
may be affected by anthropogenic stresses* How will EMAP detect
environmental change in cases where the variability of an
indicator response is not predictable?
Most of the resource groups have selected indicators.
However, no analysis has been presented that evaluates the
relationship between the selected indicators and ecosystem state.
This analysis may in part be accomplished during pilot studies
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but no rationale is given as to how the indicators might be
analyzed or how to decide the allocation of investment between
pilot studies and the operational survey*
One aspect of indicators that has not been mentioned in the
Program Plan is the coefficient of variation (CV) of indicators
among samples and over time. The CV in natural systems often
becomes greater when change is imminent before mean values change
sufficiently to detect trends. It becomes a good early warning
indicator of change. Covariance analysis and multiple regression
techniques are also useful (especially in pilot studies) in
determining which indicators are the significant ones to be
measuring. It would be useful in the section on indicators to go
into some detail to explain how indicators will be finally
selected and what purpose they will serve.
4.0 RISK ASSESSMENT AND EMM3
It was not clear from the Program Plan document or
briefing how EMAP relates to Ecological Risk Assessment, some
additional information needs to be included in the Program Plan
to explain the potential application of EMAP results to regional
and global scale Ecological Risk Assessments.
A major and positive trend in EPA's approach to
environmental protection is the incorporation of the concept of
ecological risk assessment into its monitoring and assessment as
well as its management activities. How EMAP will fit into the
assessment of relative risks is discussed superficially in the
chapter on Program Scope, but it should be integral to other
considerations of the Program Plan. In particular, this should
be a key consideration in the strategy for indicator selection,
i.e., by the selection of indicators which are subject to
exposure and susceptible to effects which characterize large
risks. Additional discussion along these lines should be added
to the indicator chapter.
(See earlier SAB reports "Evaluation of the Core Research Program
for Ecology M1PA-SAB-!PEC-90-019 and "Evaluation of the
Ecological Indicator Report for EMAP" EPA-SAB-EPEC-91-001)
The Plan needs to present a focused discussion of "Risk
Assessment," from the perspective of EMAP, in order to give
clarity to the entire EMAP mission. This should be done so as to
build the underpinnings for EMAP, The discussion of "Risk
Assessment" should come early in the Plan, present a relevant
definition of assessment, a rationale for it, and a specific list
of assessment products.
The concepts of "Indicators" will evolve to become more
functional once the products of risk assessment are known. In
addition, the criteria for selecting indicators may change from
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those currently in the Plan, and the difference between
"Indicators" and "End Points" will become more lucid.
References to ecosystem "health", "disease", and other such
analogues to the field of medicine should be dropped. The
analogies between medical sciences and ecological science are not
sound, nor are they effective in communicating specific ideas
related to the purposes of EMAP.
Based on the written documents and discussions at the
review, it is evident to the Subcommittee that some linkage has
been developed between EMAP and Risk Assessment activities within
EPA, This linkage was most evident in discussion related to the
Misk Assessment Forum activities to develop Ecological Risk
Assessment guidelines. The Subcommittee recommends that more
effort be expended by the EMAP team to examine how data developed
by EMAP can feed into the various SisJc Assessment paradigms being
considered by the RisJc Assessment guidelines development team.
Additional effort is also needed to coordinate with the
ecological risk assessment research program, particularly
research in areas of ecosystem behavior.
5.0 EMAP IMPI^OHafTATION
As noted earlier, EMAP should develop a strategy and a flow
chart to describe how data are collected and monitored.
Considerable effort should also be given to landscape
characterization (describing the physical habitats that are
associated with the EMAP sampling frames).
5.1 Defining Assessment and Integration
The Subcommittee felt strongly that any environmental
monitoring and assessment program must be fundamentally driven by
the assessment aspects rather than the other way around. That
is, monitoring should primarily be done to provide the data base
appropriate to and necessary for assessing ecological integrity.
However, there are several different levels of scientific
capabilities that can be categorized as "assessment." In one
sense, this can be visualized as a continuum, with the following,
increasingly complex levels?
Change Detection - i.e., the capability to detect
changes in the state of selected ecological
endpoints and indicators, and to characterize
those changes in the context of natural spatial
and temporal variability, that is to distinguish
the signal of change from the noise of ecological
variability.
10
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Evaluation of the Ecolectical Siqnificance of
Chancre - going beyond the statistical significance
of the previous level are issues of ecological
significance, that is, categorizing the status of
ecological resources measured by ecological
endpoints and indicators, with cognizance of
natural variability and ecological importance.
Change/Stress Association - establishing
statistical or spatial/temporal pattern
associations between particular ecological
endpoints and indicators and particular
anthropogenic stress. %
Establishment of Causality - establishing cause-
anti-effect relationships between specific changes
in ecological endpoints and particular
anthropogenic stress, with cognizance of
interactions among multiple anthropogenic
stresses, and natural variability.
Predictive Capability - all of the previous levels
are essentially interpretive and retrospective
utilizing historical and monitoring data to
establish change and causality, but predictive
capability is intrinsically prospective, and would
require development of predictive tools that go
beyond mere monitoring and retrospective
assessment -
Ecological Risk Assessment - this is a much
broader process that involves hazard
identification, eicposure characterization,
stress/response/recovery relationships specific
to both stress type and ecological endpoint,
including predictive effects assessments, risk
characterization, and risk communication*
The strong consensus of the Subcommittee is that EMAP needs
to specify clearly where along this continuum its goals and
objectives lie presently and in the future. Moreover, the
Subcommittee recognized that location along the assessment
continuum determines the monitoring capabilities, methodology
requirements, and research needs of the EMAP program. The
information provided to the Subcommittee through the
presentations, verbal dialogue, and supporting documentation does
not offer a clear picture of EMAP assessment goals? consequently,
we believe that meeting the request of the third charge to the
Subcommittee (specifically to evaluate how well EMAP can
11
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contribute to the mission of the Agency) cannot be done without
further input, review, and dialogue.
To address this issue the Subcommittee suggests the
following: EMAP needs to explore the implications of each point
along the assessment continuum with respect to: 1) monitoring
design and sampling scheme? 2) selection and characterization of
ecological endpoints and indicators; 3) assessment methodologies
and criteria for interpretation of monitoring data: 4) new
methodology development and research needs, and 5) resources that
can be brought to bear directly within EMAP and collaboratively
with other agencies, in so far as possible, the ongoing pilot or
case studies could be used to illustrate the types of issues and
level of resolution appropriate for each assessment capability.
Once the implications of this continuum are explicitly
considered, EMAP needs to pick the place or places along the
continuum toward which the program is focused. This election
will provide the basis for identifying what additions to the
present monitoring plans may be required. For example, if
detecting change is the sole goal, the present monitoring scheme
might be adequate. However, that needs to be explicitly
demonstrated through calculation of what density of information
over space or time, given natural variability, is required to
detect a specified level of change over a specified time period.
This is a calculation that apparently has not yet been made. The
Subcommittee believes that lMAP,as designed, could detect changes
and evaluate the ecological significance of changes.
If, on the other hand, a higher expectation for assessment
capability is selected for EMAP, additional components will need
to be specified? for example, to provide predictive capability to
assess the environmental effects of legislation or regulation
will require such elements as ecological modeling, more detailed
and more process oriented field data collection, and whole
ecosystem manipulations, among other approaches, and these
elements may need to be added to EMAP or developed through
specific research projects under the Core Ecological Research
Program.
Whichever level of assessment goals is selected, the
Subcommittee cautions EMAP not to oversell its program beyond
those goals. The Subcommittee feels just providing a data base
to detect and document environmental change across landscape,
regional, and national-scales is worthy goal in itself, but if
this is the selected goal for EMAP, the Program Plan should make
clear that higher level assessment activities could not be done
by EMAP and that EMAP would only be a contributor to such
assessment. The concern is that promising more than is feasible
for a particular design and level of resources can eventually
undermine the credibility and longevity of EMAP as it failed over
time to meet expectations. Limited goals need no apologies? more
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expansive goals must have concomitant monitoring and assessment
design and funding resources.
5.2 Preparation for NRG Review
1MAP is currently being reviewed by a number of scientific
bodies, including the National Research Council (NEC)* The
current description of the IMAP has focused on various aspects of
approach and procedure. However, currently the Program Pie- does
not carefully analyze the specific types or individual questions
that can be answered. A useful test of the Program design would
be to raise a number of questions concerning regional
environmental issues and then to analyze just how the questions
would be evaluated and answered from the EM&P design, without
such development, the reviews of EMAP,"1 including that from the
NRC, are sure to be difficult and raise topics for criticism.
5.3 EMAP-Landscape Characterization
The initial plans for the IMAP-Landscape Characterization
project were to describe environmental resources as statistical
populations, identify individual resource units for sampling, and
document the current status of major ecosystem types and land
uses. These objectives were to be based on the tier concept,
with the Landscape Characterization Program focusing on "Tier 1"
which is to consist of a 6% sample from 12,6000 40-sguare-
kilometer hexagons uniformly spaced across the nation.
The current EMAP-LC project appears to be somewhat
disjointed. Since many of the remaining parts of EM&P depend
upon the Land Characterization component, action should be taken
now to better focus and organize the effort. There are two
fundamental classes of problems. First, and as ably and amply
described by the June 25-28, 1990 Peer Review, there are several
technical issues which have not been addressed or which have been
incorrectly addressed. These concerns involve each aspect of the
LC program. Second, the EHAP-LC focus appears to have shifted
from addressing the demands of Tier responsibilities to ten
unrelated projects which, though each has some value, will not
collectively begin to address the issues raised by the Peer
Review Panel.
A working group should be established to assist the EMAP-LC
effort. This Working Group should consist of several experts in
geo-reference data analysis and in integration and analysis
approaches that will be required in EMAP.
6.0 SUMMARY OF RECOMMENDATIONS
For the Program Plan, the Subcommittee recommends that 1MAP
develop a long term strategy and divide the existing document
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into two parts. One part should be a short overview addressed to
the general public and the second should be an expanded version
of the plan which would explain the types of questions that EMAP
can address, the sampling strategy for EMAP, quantify the
uncertainty that may be involved in the interpretation of the
data and describe the criteria for judging the success of the
program. Because EMAP is evolving, the Program Plan should also
be subject to periodic revisions to reflect modifications and
adjustments that will be made in response to lessons that are
learned in the demonstration and pilot projects. It may be
useful to issue the plan in volumes that describe the stages in
the development of EMAP.
The Subcommittee recommends that ,more effort be expended by
the EMAP team to examine how its data can feed into various Risk
Assessment paradigms being considered for the ecological risk
assessment guidelines. The Subcommittee also recommended that
EMAP develop a flow chart of the monitoring and assessment
process to show reviewers how questions can be analyzed and
answered by EMAP.
The Subcommittee recommends that EMAP analyze its short and
long term goals for the integration and assessment of data. The
Subcommittee believes that this analysis will help EMAP to set
its directions and objectives and refine its monitoring programs*
The Subcommittee recommends that EMAP use existing data from its
demonstration and pilot projects for Forest and Near Coastal
Ecosystems for this analysis and present the results to the SAB
for review later in 1991.
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