Executive Summary

The Greater Everglades Ecosystem (GEE) of south Florida has been altered extensively to accommodate humans, industry, and agriculture. Wading bird populations have declined by 85-95 percent; 68 plant and animal species are threatened or endangered; over 1.5 million acres are infested with invasive, exotic plants; and 1 million acres are contaminated with mercury.

In response to these trends, the federal Water Resources Development Act of 1992 authorized a comprehensive review of the Central and South Florida Project to examine the potential for restoration of the Greater Everglades Ecosystem. The result of the review, known as the “Restudy,” was the Comprehensive Ecosystem Restoration Plan (CERP, referred here to as “the Restoration Plan”)—the largest restoration effort ever pursued. This National Research Council Committee on the Restoration of the Greater Everglades Ecosystem (CROGEE) was established in response to a request from the U.S. Department of the Interior on behalf of the South Florida Ecosystem Restoration Task Force to provide advice on scientific aspects of the design and implementation of the Restoration Plan.

The CROGEE's mandate (see Box ES-1) includes provision of a broad overview and assessment of the restoration activities and plans, and the issuance in reports of focused advice on technical topics of importance to the restoration efforts. One such topic is the methods by which ecological performance measures1 and system level conditions are identified for the Restoration Plan Monitoring and Assessment Plan (MAP) and the way that these measures and conditions will be used to assess the restoration process. This is an extremely important topic that the CROGEE has been concerned with almost since its inception. This report provides guidance for defining ecological targets for the restored Everglades ecosystem, suggests priorities for hydrologic and ecological monitoring of conditions in the ecosystem, and identifies aspects of establishing and administering a monitoring program that will help assure its usefulness in support of adaptive management in the Restoration Plan.

The Greater Everglades Ecosystem extends from the headwaters of the Kissimmee River southward through Lake Okeechobee and Everglades National Park into Florida Bay and ultimately the Florida Keys. It encompasses more than 46,000 km2 of subtropical uplands, lakes, wetlands, estuaries, and coastal bays, and a resident human population of 6.5 million that could double over the next 50 years. More than half of the uplands and wetlands have been

1  

These are measures that were chosen in the Restoration Plan specifically to assess ecosystem performance during and after restoration, as opposed to the more general term “indicators.”



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Executive Summary The Greater Everglades Ecosystem (GEE) of south Florida has been altered extensively to accommodate humans, industry, and agriculture. Wading bird populations have declined by 85-95 percent; 68 plant and animal species are threatened or endangered; over 1.5 million acres are infested with invasive, exotic plants; and 1 million acres are contaminated with mercury. In response to these trends, the federal Water Resources Development Act of 1992 authorized a comprehensive review of the Central and South Florida Project to examine the potential for restoration of the Greater Everglades Ecosystem. The result of the review, known as the “Restudy,” was the Comprehensive Ecosystem Restoration Plan (CERP, referred here to as “the Restoration Plan”)—the largest restoration effort ever pursued. This National Research Council Committee on the Restoration of the Greater Everglades Ecosystem (CROGEE) was established in response to a request from the U.S. Department of the Interior on behalf of the South Florida Ecosystem Restoration Task Force to provide advice on scientific aspects of the design and implementation of the Restoration Plan. The CROGEE's mandate (see Box ES-1) includes provision of a broad overview and assessment of the restoration activities and plans, and the issuance in reports of focused advice on technical topics of importance to the restoration efforts. One such topic is the methods by which ecological performance measures1 and system level conditions are identified for the Restoration Plan Monitoring and Assessment Plan (MAP) and the way that these measures and conditions will be used to assess the restoration process. This is an extremely important topic that the CROGEE has been concerned with almost since its inception. This report provides guidance for defining ecological targets for the restored Everglades ecosystem, suggests priorities for hydrologic and ecological monitoring of conditions in the ecosystem, and identifies aspects of establishing and administering a monitoring program that will help assure its usefulness in support of adaptive management in the Restoration Plan. The Greater Everglades Ecosystem extends from the headwaters of the Kissimmee River southward through Lake Okeechobee and Everglades National Park into Florida Bay and ultimately the Florida Keys. It encompasses more than 46,000 km2 of subtropical uplands, lakes, wetlands, estuaries, and coastal bays, and a resident human population of 6.5 million that could double over the next 50 years. More than half of the uplands and wetlands have been 1   These are measures that were chosen in the Restoration Plan specifically to assess ecosystem performance during and after restoration, as opposed to the more general term “indicators.”

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BOXES 1 Committee on Restoration of the Greater Everglades Ecosystem Statement of Task This activity provides scientific guidance to multiple agencies charged with restoration and preservation of the Central and South Florida aquatic ecosystem, i.e., the Greater Everglades. The NRC activity provides a scientific overview and technical assessment of the many complicated, interrelated activities and plans that are occurring at the federal, state, and nongovernmental levels. In addition to strategic assessments and guidance, the NRC provides more focused advice on technical topics of importance to the restoration efforts when appropriate. Topics such as the following (to be determined to the mutual agreement of the restoration program management and the NRC) are expected to form the bases for the committee’s investigations: Program goals, objectives, an planning approach; Data and information aspects, including needs for basic hydrologic and water quality data, environmental resources information, display and dissemination, and monitoring needs; Use of hydrological and hydroecological simulation models; Technological aspects of civil works facilities; Best agricultural and management practices of nutrients management; Wildlife management; Decision support systems; and Research requirements to support analyses for decision making and implementation. converted to urban and agricultural uses, and the remainder is highly engineered, intensively managed, and tightly bounded by development. The fundamental premise of the Restoration Plan is that restoring the historical hydrologic regime to the remaining wetlands will reverse declines in many native species and biological communities. To “get the water right”—a major goal of the Restoration Plan that involves quantity, quality, timing, and distribution of water—the plan proposes construction of 68 major projects over an estimated 36 years at a cost of $7.8 billion (1999 estimate). How Everglades ecosystems will respond to the restored water regime is quite uncertain, so extensive ecological research, monitoring, and adaptive management are planned during construction and after the projects are completed. The ultimate success of the Restoration Plan hinges on a well-designed and well-supported program of monitoring and assessment, the subject of this report. Such a program, now in development, is expected to consist of five major sections: 1) identification and measurement of ecological indicators, 2) design of the monitoring network, 3) implementation plan for sampling, 4) analysis of the indicators to assess ecosystem response, and 5) research to support the monitoring and assessment activities. To date, most of the development effort has focused on identifying ecological performance measures. Because the “Monitoring and Assessment Plan” (MAP) is still evolving, this report does not dwell on specific performance

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measures or protocols but instead reviews the general approach and design of MAP. As a result, it is likely that some of the recommendations of this report are already being pursued.2 Implementation of the Restoration Plan is to follow an adaptive management strategy and, appropriately, the MAP is designed to inform the adaptive management process. Accordingly, this report assesses the extent to which the MAP includes four critical elements of an adaptive management scheme3: (1) clear restoration goals and targets, (2) a sound baseline description and conceptualization of the system, (3) an effective process for learning from future management actions, and (4) explicit feedback mechanisms for refining and improving management based on the learning process. SETTING GOALS AND ECOLOGICAL TARGETS FOR THE EVERGLADES ECOSYSTEM The goals, targets, and measures of the Restoration Plan are based on considerable analysis and political and scientific judgment. However, building broad stakeholder support for the program has been achieved in part by promoting goals and targets that may not be entirely achievable or even internally consistent. In particular, the following issues have emerged from discussions with scientists, managers, and others involved in the restoration endeavor: Some of the specific restoration goals may be at odds with the general goal of ecosystem restoration (for example, managing water levels for a particular endangered species). Restoration targets have not been reconciled with large-scale forces of change in south Florida, especially population growth, land-use change, and sea level rise. Targets and measures have not yet been defined for the broad goal of achieving compatibility of built and natural systems. There appear to be competing visions of what “success” actually means. The Central and South Florida Restudy Alternative Evaluation Team (Restudy Alternative Evaluation Team {AET} 1998) described the desired outcomes of the restoration in qualitative terms that are compatible with long-term, large-scale ecological restoration based on adaptive management. However, a large number of quite specific targets have also been identified and promoted. Scientists involved in the restoration recognize that many of the specific targets, which have been set using historical evidence, conceptual models, and dynamic hydrologic and ecological simulation models, provide little more than educated guesses at where, when, and how populations and communities will respond to restored hydrologic conditions in a reduced system that has been extensively invaded by exotics species. Furthermore, the targets do not incorporate possible ecological tradeoffs as restoration activities operate to benefit one species or locale to the detriment of another. A challenge for the Restoration Plan, as for any long-term environmental project, is to reconcile goals and targets with exogenous forces of change: regional sea-level rise and climate change, national and international factors that cause local economic change (e.g., sugar 2   A substantially revised version of the MAP, prepared by the RECOVER Adaptive Assessment Team, will be provided by the U.S. Army Corps of Engineers and South Florida Water Management district for public and agency review during April and May 2003. 3   The Restoration Plan and MAP are using passive adaptive management, i.e., they are not using the restoration project as an experiment or deliberate manipulation for scientific purposes.

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subsidies and trade regulations), changes in federal law or international treaties, and so on. The Restoration Plan does not consider multiple scenarios of change or how the restoration itself could influence human activities, which could in turn affect the restoration. Also, until targets and measures are set for defining compatibility of the built and natural system, the Restoration Plan will not have explicitly addressed possible tradeoffs and conflicts between ecological restoration and other policies, statutes, and social demands. In addressing the Restoration Plan’s objectives, then, and especially in designing a monitoring and assessment program, scientists involved in the restoration should consider the degree to which the following general issues are important: What are the critical human and climatic forces driving or affecting restoration? To what extent and with what precision can science and modeling examine proposed alternative restoration project scenarios? What social dynamics of importance are outside the management boundary and how should these be analyzed and monitored? RESTORATION REFERENCE STATE The restoration reference state—that is, the condition of the ecosystem used as a reference to evaluate the success of the restoration—is important but challenging to establish. The Everglades has changed and will continue to change due to long-term changes in climate and sea level independent of human impacts or restoration efforts. Further, the system is still adjusting to recent changes in drainage and water quality. All these factors make it difficult to choose an appropriate restoration reference state. Scientists associated with the restoration have sought to define reference conditions using a mix of modeling and empirical studies. Despite considerable progress, there is a need for continued research to better conceptualize and describe the reference state, research that goes well beyond performance monitoring. This does not mean that the Restoration Plan should not proceed without a better-defined conceptualization of the restoration reference state. It does suggest, however, that the adaptive assessment strategy should include monitoring in support of improved “baseline” data and model outputs as well as hypothesis-driven research to validate the underlying cause-effect relationships defined in the MAP conceptual models. LEARNING THROUGH INTEGRATED MONITORING, MODELING, AND RESEARCH The MAP has been structured to monitor the hydrologic conditions in the system and the ecosystem response to them. The ecological performance measures will be used to monitor the status of what the Restoration Plan calls five functional groups identified by the program scientists as critical to understanding ecosystem response to the CERP: wetland trophic relationships, wetland landscape patterns, estuarine epibenthic communities and habitats, Lake Okeechobee pelagic and littoral zones, and biota of special concern (i.e., threatened or endangered species).

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Hydrologic Performance Measures The Restoration Plan is guided by solid scientific research and understanding. Nevertheless, there is much that remains unknown about current and historical hydrologic conditions and their relationships to ecological patterns and processes. Knowledge gaps include the role of environmental variability in establishing and maintaining the Everglades, hydrologic linkages between groundwater and surface water, average and extreme water flows and their role in the ecosystem, and the implications of historical and current loss and fragmentation of upland habitats for many species. An initial list of approximately 900 hydrologic and water-quality performance measures had been reduced to 78 in the MAP at the beginning of this study (fall 2001). These measures are not response variables in the same sense as the ecological performance measures and functional groups. Rather, they are measures of factors identified as stressors in the regional conceptual models. There are several limitations to the existing set of hydrologic performance measures with respect to their use in an adaptive assessment framework. First, the present measures will be of limited value when applied prior to the implementation of critical features of the Restoration Plan. Even after the Restoration Plan has been completed, observed measures will be confounded by temporal variability in water flows and levels due to climatic variability. An additional limitation of the current hydrologic performance measures is that they cannot be aggregated to provide an overall measure of system performance. Fortunately, these limitations can be readily addressed. The hydrologic model can be used in such a way that observed climate and the status of the Restoration Plan implementation are used as input data for it. An “aggregate” measure can be derived by using hydrologic model outputs as attributes of “ecological habitat suitability functions” for selected ecological indicators. Ecological Performance Measures The proposed monitoring plan is based on indicators of the current status of the ecosystem (baseline) and, as the Restoration Plan is implemented, of populations (e.g., threatened, endangered, and invasive species), communities (e.g., tree islands), and ecosystem functioning (e.g., net primary productivity and formation of soil organic matter). This hierarchical approach will provide a relatively comprehensive evaluation of the system’s ecological response to restoration projects and changing environmental conditions as well. The challenge in developing the MAP is selecting appropriate, practical, and informative indicators. If they are well chosen, they should also provide a context or framework for choosing and interpreting more specific indicators. The five chosen categories of performance measures reflect the five restoration goals outlined above. However, they do not fulfill the need for system-wide indicators. The current monitoring plan would benefit from a few ecosystem-level, system-wide indicators. The number of indicators chosen to monitor could be reduced by concentrating on poorly understood processes, performing sensitivity analyses to see which uncertainties have the largest effects on model outputs, and by aggregating site-specific variables into a smaller number of system-wide variables where possible. The MAP could consider monitoring spatio-

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temporal patterns of total species diversity as well as of native species diversity. Additionally, given that the Restoration Plan is focused on a well-defined ecosystem, an IBI (Index of Biotic Integrity)-like measure would be appropriate and useful. The purpose of such a measure would be to provide a “multimetric” that would integrate several key indicators to represent the changing structure and functioning of the Greater Everglades Ecosystem. Indicators also are needed to provide information about ecosystem functioning in a broad sense and give information about the ecosystem’s capacity to respond to changes. Understanding the Relationship of Drivers to Restoration Targets and Measures Ecosystem drivers (such as climate and sea-level changes, changes in development patterns, and land-use changes) must be monitored in addition to ecological performance measures. The focus should be on system drivers that have long-term excursions from average (e.g., weather cycles) or trends (e.g., sea-level change). This is necessary because system response times may be quite different than anticipated when the ecological models used in the Restoration Plan were developed. Furthermore, to understand the Greater Everglades Ecosystem (and subsystem) response to the Restoration Plan, it will be critical to monitor changes in anthropogenic drivers because of the strong effects they may have on the hydrologic and ecological performance measures. Given the expected long time scales of the Restoration Plan’s activities and ecosystem response to them, hydrologic and ecological models will likely remain a primary design and evaluation tool for projects and monitoring programs. Driving variables for these models should be explored over a range of scenarios to assess the “robustness” of the Restoration Plan to future changes. Setting Monitoring Priorities The MAP does well at reducing a large number of possible measures and monitoring objectives down to a much smaller, but still substantial, subset. The MAP should further set priorities within this subset, reflecting the relative utility of elements of the subset in meeting the several monitoring objectives (i.e., adaptive management, report card, and regulatory compliance). Priorities also are needed for choosing the ecological indicators. Characteristics of indicators that should be considered in setting these priorities include the following: relevance to restoration goals, potential to help identify critical knowledge gaps that are most critical to the largest number of future projects, relevance to predictive models, importance to stakeholders, sensitivity to the design and operation of the Restoration Plan when “normal” variation is known, and technical feasibility.

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Annual Report Card In addition to monitoring for adaptive management, selected variables will be monitored to produce a restoration “report card.” Ten indicators of water quality, population abundance, and habitat extent have been identified. The report card is a useful idea, but report cards should make clear that variations in the measures and unexpected results may result from influences unrelated to the Restoration Plan. Monitoring of the report card elements should be accompanied by research that establishes the cause-effect relationships between the measure and environmental variation as well as variation in these “outside” influences. Regulatory Compliance Monitoring Several federal environmental laws apply to the Everglades, for example, the Endangered Species Act (ESA), the Clean Water Act, and the National Environmental Policy Act. State laws apply as well. Thus, in addition to focusing on the ecosystem, the MAP will need to meet the information needs of each of the organizations and agencies involved in the Restoration Plan. The Everglades system contains populations of several endangered species, and some of the monitoring described within MAP is necessary to comply with the ESA. Achieving water quality standards is part of “getting the water right,” and thus monitoring water quality is not only essential to adaptive management, but it is also a regulatory requirement in some cases. Modeling and Experimental Research Hydrologic and ecological simulation models have guided the restoration design and will be important in integration and evaluation of monitoring data and adaptive management. The ecological modeling efforts have not received as much support for development, refinement, and input data as the hydrologic models. A well-supported ecological modeling component that is coordinated with hydrologic modeling and field monitoring is important to the success of adaptive management. SCIENTIFIC FEEDBACK TO THE RESTORATION PLAN Although six management options are recognized in the Restoration Plan as being informed by monitoring and assessment activities, in practice, there will probably be limited opportunities for adaptive management in a program as large and complex as the Restoration Plan, because there are long time lags between the design and implementation of restoration activities. In addition, ecosystem response times can be on the scale of decades or more. Well-designed pilot studies and monitoring, with experimental research and modeling, can provide meaningful scientific feedback for management and decision–making. This would require strong communication between scientists and managers, and institutional flexibility to respond to new information.

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Synthesis of monitoring data and preparation of adaptive management reports are important to the Monitoring and Assessment Program. While the development of these parts of the program is in its early stages, the following questions should be asked. How often should formal reviews of the Restoration Plan’s performance be conducted? Are there specific ecosystem responses that will trigger a formal review, in addition to scheduled reviews? Is enough time for analysis and synthesis of information built into the assessment process? How will independent peer review of data collection and synthesis be conducted? Who will make sure that monitoring results are incorporated into the implementation of the Restoration Plan, and how will that be done? DATA MANAGEMENT AND PRODUCTS The scope and complexity of the monitoring requirements of the Restoration Plan warrant the direction of special attention and resources to a quality assurance/quality control (QA/QC) program whose elements include planning, implementation, assessment, and reporting. Data-quality objectives (DQOs) should be established during the planning stage of the program and used to develop measurable performance criteria. Successful planning will allow managers to identify financial, personnel, and information technology resources needed for implementation, assessment, and reporting. Since monitoring performance indicators and QA/QC performance objectives are intimately related, adding DQOs incrementally to an existing monitoring plan could prove wasteful and inefficient. The development of a plan for data and information management has lagged behind other elements of restoration planning. But adaptive management cannot succeed without reliable access to well-documented, validated information. CONCLUSIONS AND RECOMMENDATIONS Conclusion: The Comprehensive Everglades Restoration Plan (Restoration Plan) Monitoring and Assessment Plan (MAP) is grounded in current scientific theory and practice of adaptive management. The least developed aspects of the planned adaptive management are feedback mechanisms to connect monitoring to planning and management. Recommendations: Adaptive management should not simply mean “flexibility in decision making under uncertainty.” When considering a variety of possible strategies, actions should be taken that are informative, reversible, and less uncertain or at least robust to uncertainties. Institutional mechanisms should be created and sustained to ensure that scientific information is available and accessible to the decision-making process.

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Opportunities for flexibility in design should be identified and operational features of the Restoration Plan components should be assessed to help prioritize monitoring and assessment activities. Conclusion: Restoration goals, objectives, and targets for the Everglades are inadequately defined and are not reconciled with the large-scale forces of change in south Florida. Recommendations: Targets should be set as soon as possible that define the extent of compatibility between the built and natural systems and that address possible conflicts between ecological restoration and other policies, statutes, and social demands. Research and monitoring should continue to better conceptualize and describe current conditions in the Greater Everglades Ecosystem. Continued support and coordination of hydrologic and ecological monitoring and coordination among them are important components of monitoring and assessment. Integrated modeling is the best method for extrapolating findings over large areas and long periods. Since the Everglades can never be fully restored, probable conflicts among desired ecological targets should be identified, necessary compromises should be acknowledged, and the scope of the MAP should contemplate this line of inquiry continuing for the duration of the restoration (so emergent conflicts can be resolved appropriately). Conclusion: Adaptive management requires an effective process for learning from management actions. The primary reliance on passive adaptive management planned for the restoration may be the only feasible approach given the large time and space scales of the project and constraints such as those imposed by endangered species. Passive adaptive management uses science to formulate predictive models, makes policy according to the models, and revises the models as data become available. But monitoring is done without controls, replication, and randomization, and thus it lacks statistically valid experimental design, and therefore cannot always be used to infer cause and effect. Policy effects are not distinguishable from other human forces or from natural processes. Recommendation: The MAP should be augmented with active adaptive management wherever possible to enable conclusions about cause and effect to be made. As soon as possible, additional expertise in sampling design and analysis of environmental data should be engaged. Opportunities should be identified for active adaptive management that compares alternative policies by means of deliberate experiments. The experiments should use controls, paired comparisons, replication, and randomization.

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Conclusion: The MAP needs a rigorous quality assurance/quality control (QA/QC) program to ensure that monitoring data are of high quality and utility. Recommendation: To ensure the quality of RECOVER environmental data and related data products, a QA/QC program with clearly defined roles and responsibilities should be established. The current Restoration Plan Program Management Plan for Data Management calls for such a function, but it appears that there has been little substantive progress in this important area. The National Institute of Standards and Technology or other similar organization should be consulted to provide guidance as a QA/QC plan is developed. Conclusion: Including combinations of ecological performance measures and environmental variables hypothesized to impact those measures is critical for the MAP given the adaptive management approach being implemented. Recommendations: More ecosystem-level, system-wide performance measures or indicators (such as defined by NRC, 2000) should be identified and set. For example, more use could be made of the nine broad targets developed by the Restudy Adaptive Assessment Team (AAT). Other possibilities include land-cover and land-use measures, an Index of Biotic Integrity, and system-wide diversity measures. Monitoring of invasive species, mercury, and other contaminants should be added. Hydrologic performance measures useful in designing the Restoration Plan should be modified to better serve adaptive management. New aggregated performance measures will be especially critical. Conclusion: Region-wide monitoring of ecosystem drivers is essential to reducing the uncertainties associated with the Restoration Plan but these drivers appear to have received comparatively little attention by the Monitoring and Assessment Program. Recommendations: To understand better the potential effects of restoration decisions in the Greater Everglades Ecosystem and the Restoration Plan, the external human and environmental drivers of the system, such as human population growth, water demand, and long-term climate, should be monitored and their contributions to ecosystem response should also be assessed through experimentation as well as modeling. Many of them already are monitored by local, state, and federal agencies and so the main challenge will be to coordinate an integrated modeling, monitoring, and experimentation effort that makes good use of such data. Given the expected long time scales of ecosystem response (as well as the extended implementation time scales), models of hydrologic processes and ecological responses, adaptable to new situations and new stressors, will remain a primary design and evaluation tool

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for projects and monitoring programs. External drivers for these models should be varied over a range of scenarios to assess the “robustness” of the Restoration Plan to future changes. Conclusion: Effective adaptive management requires an explicit feedback mechanism for learning from management actions. Scientists developing the monitoring and assessment plan need an explicit understanding of what information to management needs and how monitoring results will be used Recommendations: To create a basis for scheduling and sequencing of projects within the Restoration Plan, an assessment of the design and operational flexibility of the 68 proposed major projects could be used to prioritize monitoring, experimental, and modeling activities. Therefore, it should be determined which project components have the greatest impact on decisions, and hence on monitoring activities. In other words, the relative ease with which projects could be modified in an adaptive management process should be assessed. Therefore, monitoring and process studies should include hydrologic and ecological features for which improved prediction of response could lead to project modification that will improve the restoration outcome. Formal linkages should be established to connect the RECOVER Senior Management Team and the Science Coordination Team to the CERP decision-makers to keep them informed of the changing state of knowledge, so that they can make decisions based on current scientific information. Conclusion: In addition to serving adaptive management, the monitoring program must also serve compliance monitoring and report card functions. Recommendations: The strategy of integrating, but differentiating, performance measures used for adaptive management, compliance monitoring, and the report card is a worthy one. The MAP should determine on a continuing basis the most effective ways of communicating and explaining scientific information to the decision makers and various stakeholders related to the restoration of the Everglades using adaptive management. System-wide performance measures sensitive to restoration activity and associated with low uncertainty should be included in the report card. It is appropriate to use visible measures of interest to the public, such as abundance of endangered species, in the report card but these will not be sufficient to show positive progress toward restoration. It is appropriate to include compliance monitoring in the adaptive management framework when the performance measures involved will be affected by the Restoration Plan. However, in other cases performance measures will be driven by other factors (e.g., populations of some endangered species), and monitoring of these should be clearly labeled as compliance in nature.

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Conclusion: The overall design and funding of the Restoration Plan obviously requires adequate and continued support of long-term monitoring and scientific studies throughout the restoration. At this time funding of monitoring activities appears secure and ample. Still, funding is never unlimited, and it is therefore critical that Adaptive Assessment Team develop strategies for prioritizing monitoring needs of all kinds. This includes prioritizing the importance of the various ecological indicators. The Adaptive Assessment Team has done an excellent job of winnowing a large number of possible indicators and monitoring objectives down to a much smaller, but still substantial, subset. Recommendation: The Adaptive Assessment Team should prioritize within this subset of monitoring objectives, and consider the relative utility of elements of the subset in meeting the several monitoring objectives (i.e., adaptive management, report card, and regulatory compliance).