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The Role of Monitoring in Environmental Management THE IMPORTANCE OF MONITORING Why Monitor? The ultimate goal of environmental monitoring of all kinds compli- ance, model validation and verification, and trends is protection of the environment, living resources, and human health. Monitoring provides information that is useful in managing the environment, its resources, or human activities affecting them. Environmental monitoring data document existing conditions and, if collected repeatedly, chronicle changes in these conditions. Absent knowledge of prior environmental conditions, monitor- ing establishes a starting point for future comparisons. Monitoring is most beneficial when it results in more effective man- agement decisions-decisions that protect or rehabilitate the marine envi- ronment, its living resources, and uses or resources that society considers important. For example, monitoring coliform bacteria as an indicator of human fecal contamination has been an effective public health measure for decades, triggering direct management actions to close beaches to swimming or shellfish beds to harvesting or to eliminate or improve the treatment of sewage discharges. Other uses of monitoring results include: · Providing environmental managers with a rationale for setting stan- dards. When monitoring results show a clear change or trend, for example, a reduction in fish abundance, public confidence in the decision maker's limits on catches is enhanced. 19
20 MANAGING TROUBLED WATERS · Constructing, adjusting, and verifying quantitative predictive mod- els that can be the basic tool used in evaluating and selecting management strategies. · Determining compliance with regulations and conditions set by permits. · Providing the information needed to evaluate pollution abatement programs. . Early warning of future problems when they can be resolved more easily and at lower cost than if left unattended. Although monitoring cannot guarantee early detection of problems, it can reduce the probability of unpleasant surprises. . Enhancing knowledge of marine ecosystems, their variability, and society's impacts on them. With this information, managers can shift pri- orities and reallocate resources when necessary to match the management agency's resources with important and tractable environmental problems. · Engendering a better understanding of the health of the marine environment. Decision makers and the public want answers to pressing questions. Is water quality getting better or worse? Are fish and shellfish increasing or decreasing in abundance? Is it safe to swim? lb eat the fish? Are conditions stressful to marine organisms increasing or decreasing in frequency, extent, and duration? The Costs of Not Monitoring The costs of not monitoring-or of monitoring ineffectively-include failure to obtain the information needed to assess environmental conditions, to validate and verily predictive models, and to chronicle changes in the environment resulting from natural variations, management actions, and pollution impacts. In short, the cost of not adequately monitoring is a seri- ous shortcoming in our efforts to protect and restore marine environmental quality. The economic, social, and political costs of failing to detect and deal with environmental problems in the early stages can be enormous. Econom- ically, correcting problems after the environment is seriously degraded adds to the costs. But some degradation may be irreparable: living resources may be so depleted and habitats so damaged that stocks of commercially and recreationally important species may never return to predegradation levels. Public health problems can arise, with attendant economic and so- cial consequences. Public opposition and anger may increase with sudden news that beaches are unsafe for swimming or fish and shellfish are unsafe to eat. Government agencies and their officials may be blamed for neglect or short-sightedness.
THE ROLE OF MON~OMNG IN E~RONMENT~ MANAGEMENT 21 Limitations of Monitoring It is important not to overstate the usefulness of monitoring programs. The marine environment is complex and variable. In coastal regions, separating impacts of human origin from natural variability is difficult. This difficulty and others do not argue against monitoring the marine environment, but they do make the case for realistic expectations, careful and critical experimental design, periodic evaluations, and a constancy of commitment. Often the causes of environmental problems, whether natural or human-induced, cannot be identified unequivocally even with data and information gathered from well-designed monitoring programs. A recent example of the limitations of monitoring in effectively addressing public concerns is the issue of ocean dumping in the New York Bight. During the summer of 1988, stranded wastes on beaches, unusual deaths of dolphins, diminished fish stocks, and reports of lesions on the shells of crabs and lobsters elevated public suspicion that the culprit was dumping of sewage sludge, the approved site for which had recently been relocated from 12 miles to 106 miles offshore. Despite an extensive background of studies of ocean dumping in the New York Bight and the considerable monitoring being conducted, it was not possible to say without doubt whether the observed phenomena were due to ocean dumping or other causes. Re- flecting the public's concerns, Congress acted swiftly by passing the Ocean Dumping Ban Act of 1988. Although it can be argued that an improved or more extensive monitoring program could have resolved the issue more effectively, the example points out the inherent limitations of monitoring in linking unexpected phenomena to their causes. The complexities of the problems, variability in natural systems, and the time needed to conduct research and acquire information on marine processes and systems make absolute determinations extremely difficult. Risk-free decision making is an impossible goal. Monitoring programs can narrow uncertainty, not eliminate it. They can contribute to under- standing change and to ascribing causes to these changes, and their results are useful in weighing the societal benefits of management alternatives. The Evolution of Monitoring Over the past two decades, several studies closely evaluated monitoring and criticized its lack of quality assurance and cohesiveness and its ability to provide information that answered decision makers' questions (e.g., Wolfe 1988; Beanlands and Duinker 1983, 1984; Walters 1986; Cairns, Dickson, and Maki 1978~. Partly because of these evaluations and partly because
22 MANAGING TROUBLED WATERS of environmental awareness and regulation, monitoring has improved. Be- cause they are required by law or regulation, many compliance monitoring programs now enjoy secure funding. As a result, these programs have been refined to include a high level of quality control, consistency in sampling and analytical techniques, and clearer presentations and syntheses of data and conclusions. This fact has attracted many qualified scientists to some of the larger monitoring programs. Perhaps the best example of this evolution is in Southern Califor- nia, where compliance monitoring around wastewater outfalls began in the 1950s. Initially, the programs, implemented by municipal wastewater treatment authorities, suffered from lack of staff training, little support or recognition from funding agencies, and inadequate equipment. In 1969, the large dischargers formed the Southern California Coastal Water Re- search Project (SCCWRP), which introduced the concept of regionwide quality assurance. As a result, staff members from the publicly owned treatment works (POTWs) shared ideas, trained new employees, developed new and improved equipment and techniques, and worked with researchers at SCCWRP to develop technologies and approaches to synthesize and summarize findings. Success Stones in Monitoring The following examples of monitoring to protect public health, validate water quality models, and evaluate pollution abatement have two common characteristics. In all cases, monitoring provided clear and important input to management decisions, and it was targeted at issues that the public and decision makers recognized as important. These examples relate primarily to the impacts of point sources on estuarine water quality and the im- provements effected by waste treatment facilities. They demonstrate other factors that led to successful monitoring: the specificity of the water qual- ity problem, a relatively well-defined estuarine system, the availability of historical data, the collection of additional data relevant to the problem, and, most important, an understanding and quantification of the relation between mass emissions from human-induced and natural sources and the environmental response. For broader issues in the marine environment, many of these elements are lacking, particularly adequate historical data and an understanding of ecosystem responses. Protecting Public Health During the 1920s, prior to the National Shellfish Sanitation Program and the extensive monitoring of fecal coliform bacteria in shellfish-growing waters, gastroenteritis and hepatitis periodically caused significant public health problems. Besides using coliform counts for closing shellfish beds
THE ROLE OF MON~ORING IN ENKIRONMENT~ ~AGEMENT 23 to direct harvest, the abundance of fecal coliform bacteria is also used for closing or limiting the use of bathing beaches and requiring waste treatment. There continues to be a debate over the appropriateness of the conform standard as an indicator of the possible presence of pathogens, but outbreaks of gastroenteritis and hepatitis associated with the consumption of shellfish are now rare. Although there is need to develop methods that more directly measure the pathogens of concern rather than using an indicator organism, Escherichia colt, it is clear that much illness has been avoided by fecal coliform monitoring. Needed improvements in pathogen detection could allow beach-closing decisions to be more specific to local conditions, and they offer the possibility of opening shellfish beds to harvest should the coliform standards prove to be too conservative. Validating Models: Examples from Modeling Estuarine Water Quality One measure of successful monitoring is its contribution to better management decisions. An important use of monitoring results is to calibrate, validate, and verify mathematical models used to forecast the consequences of implementing different management strategies. Because predictive/deterministic models express our understanding of how ecosys- tems typically function and respond to stress, monitoring to validate models and verify predictions is essential for improving that understanding. Models validated with monitoring data may be used to select a management option. Water quality modeling, which initially focused on biological oxygen demand (BOD), dissolved oxygen (DO), coliform bacteria, and other tradi- tional parameters, has become increasingly sophisticated in recent decades. The original contribution of Streeter and Phelps (1926) on DO in fresh- water streams was used to determine the degree of wastewater treatment required to maintain acceptable levels in the Ohio River. These basic concepts were incorporated in estuarine water analyses (O'Connor 1960; Thoman 1963; Helling and O'Connell 1967) and subsequently extended to incorporate problems associated with eutrophication (DiToro, O'Connor, and Thoman 1971~. Efforts are now directed to the transport and fate, including accumulation in food webs, of toxic substances. Application of these concepts to water quality planning was initially directed to reducing input from point sources. Increased understanding of the basic phenomena affecting water quality is now providing a basis for analyzing the effects of nonpoint sources. Monitoring has been used for water quality model validation and subsequent planning in many estuarine systems throughout the country (e.g., Boston and New York harbors, the James River, the Sacramento-San Joaquin Delta, and the Potomac and Delaware estuaries). In Boston Harbor, a water quality model validated by monitoring data for pre- and post-treatment conditions was used to evaluate the relative
24 MANAGING TROUBLED WATERS impacts of treatment plant effluents, sludge discharges, and stormwater overflows. The data were collected after upgraded treatment facilities had been installed; the significant improvement in water quality with reference to bacterial concentration was consistent with model calculations. The model was then used to define the relative effects of sludge discharges and stormwater overflows. Thus the monitoring data, with the model, were a tool for assessing additional remedial measures. New York Harbor monitoring data were used in mathematical models to forecast DO levels expected with construction of new wastewater treat- ment plants. These models helped in planning the upgrade and installation of treatment facilities. After the plants were in operation, the predicted improvements in DO compared well with observed conditions. The models were subsequently used in evaluating additional upgrading of the waste treatment plants and preliminarily assessing the impacts of combined sewer overflows and urban runoff on water quality. As a component of an on- going management program that is addressing these nonpoint problems, more recent monitoring data will be used to improve the model. Numerical models of the James River, a tributary estuary of the Chesapeake Bay, used monitoring data in support of management decisions about whether to attempt to remove kepone-contaminated sediments or to leave them In place to be buried naturally and how to conduct maintenance dredging of navigation channels. In the Sacramento-San Joaquin Delta, estuary monitoring data were used to calibrate and verify mathematical model prediction of salinity distri- bution as it might be influenced by freshwater diversions from San Francisco Bay. These model results have been considered in major decisions regard- ing the allocation of freshwater resources in California. Similar models have been applied to Texas estuaries in freshwater resource allocation decisions. Modeling the effects of freshwater diversion of the Sacramento River on the eutrophication of the Sacramento-San Joaquin Delta began in the early 1970s. Initial field measurements provided the data to calibrate a model of the nutrient-phytoplankton ratio, which was used to establish the monitoring program. Validation of the model with subsequent data yielded results in general accord with the observations. During the extreme drought of 1976-1977, however, the salinity level rose, disrupting phytoplankton levels and markedly affecting other levels in the food chain. These effects were not anticipated by the model because the scientific understanding of this complex physical and biological interaction was lacking. Monitoring data supplemented by experiments helped scientists un- derstand the changes that had occurred. Monitoring data provided the basis for introducing in the model a new variable to account for observed changes. The improved model provided a quantitative means consistent with scientific understanding of analyzing the reduced productivity under
THE ROLE OF MON~O~NG IN E~RONMENT~ ~AGEMENT 25 conditions of increased salinity intrusion. This example demonstrates the interaction and feedback between the research and applied elements of a program that go on as the scientific understanding of environmental phenomena increases. It further exemplifies the need for flexibility in the continuous development of monitoring and modeling with respect to the collection of field data, the design of laboratory experiments, and the syn- thesis of the results. This interaction is fundamental to any water quality monitoring program, as are the close cooperation and open communication among the scientists and engineers representing these areas of expertise. Both flexibility and parallel development of monitoring and modeling are needed to validate the model. Assessing the E~ecaveness of Pollution Abatement A classic example of monitoring the effectiveness of pollution abate- ment in the coastal environment concerns improvements in water quality and recovery of biological populations in the Thames estuary below London (Gameson and Wheeler 1977; Thames Survey 1964~. Similarly, monitor- ing has documented significantly improved water quality, particularly DO concentrations, due to new and upgraded wastewater plants in New York and along the Delaware River estuary. Extensive monitoring performed by municipal dischargers and other public agencies in the Southern California Bight provides other examples of the effectiveness of pollution abatement (NRC in press). Lower particulate and organic levels reduced the size of the zone of heavy sediment contamination and altered benthic communities at the Los Angeles County wastewater treatment outfall off White Point and may have contributed to the return of kelp beds off the Palos Verdes Peninsula. Lower concentrations of DDT and its metabolites in fish and shellfish have been observed following the limitations on its use (Mearns et al. 1988~. INSTITUTIONAL DYNAMICS OF MONITORING Throw together . . . law enforcement officers, ecological researchers, . . . statisticians, policy planners, resource biologists, administrative per- sonnel, and perhaps quite a few others. Call this a management agency. Now "interface" it somehow with its constituents, ranging from politi- cians worrying about the next election, to concerned conservationists, to careful business entrepreneurs, to "cowboys" out to take the biggest catch this year.... Finally, consider the resource itself, a complex ecological system that is too expensive to monitor thoroughly, changes unpredictably in response to environmental factors, and generally offers all sorts of conflicting signals that are open to every interpretation from imminent disaster to grand opportunity. There you have the modern management situation (Walters 19S63.
26 MANAGING TROUBLED WATERS As Walters's irreverent observation illustrates, environmental man- agement-and, as a component of management, monitoring programs- operate within institutional and technological limitations. The experiences of marine monitoring professionals around the country, as well as the case studies conducted as part of this evaluation, indicate that political, legal, and bureaucratic considerations are at least as important as technical and scientific considerations in determining the success or failure of monitoring programs. Institutional interactions are discussed in the following sections. Understanding ecosystems and variability is clouded by the technical lim- itations of making the right measurements on the right space and time scales. This often poorly defined picture is further confused by the many expectations, viewpoints, and interpretations of the diverse parties involved, from the general public to highly qualified technical specialists. A variety of institutions with different mandates and contributions sponsor marine environmental monitoring and use the information gener- ated by monitoring programs. The Principal Players Involved Parties involved in monitoring include local, state, and federal regu- latory and resource management agencies; harbor and port agencies; reg- ulated dischargers; developers; scientists associated with consulting firms and universities; and the interested public and their elected representatives. Their responsibilities and interests, which often overlap, are described be- low. The following sections analyze why and how their interactions make the system work the way it does; recommendations for improving specific problems are then made. Ideally, government agency interests in marine environmental monitor- ing focus on obtaining high-quali~ information useful to making decisions necessary to fulfill mandated responsibilities. These responsibilities include marine resource management, regulation, education, and research. Regulated ocean dischargers and developers of ocean resources gen- erally conduct or finance monitoring programs either because they are required to do so or because they want to provide information for decision makers and the public (or themselves) about the nature and effects of their discharges and other activities. The interests and objectives of ocean dischargers and developers include generating information that will help reduce the regulatory burden, promoting a positive public image, reducing operating costs, and aiding future decision making. All dischargers and developers share the common objectives of supplying required informa- tion at a minimal cost and seeing that the information generated is used constructively. Scientists from government and educational or private organizations
THE ROLE OF MON~O~NG IN EN~RONMENT~ MANAGEMENT 27 often design and implement monitoring programs. They have interests in using monitoring to increase their understanding of the patterns and processes of nature and to advance their technical capabilities. The interested public includes a broad variety of individuals and groups, including environmental organizations, fishermen, fish-consumers, coastal and marine recreationists, and associated businesses. Their interests in monitoring range from furthering economic goals (e.g., promoting fish consumption or ocean recreation) to furthering political ends (e.g., legis- lation imposing stricter controls on dischargers) to concerns about human health and safety (e.g., is the water safe for swimming?) to aesthetic and philosophical concerns about the marine environment. Elected officials and appointed members of the executive branches of government are responsible for enacting legislation, setting policy, and con- trolling agency finances. Elected officials mainly influence marine monitor- ing programs by developing and modifying legislation that requires marine monitoring activities and by controlling the budgets of agencies responsible for the monitoring programs. These officials also bring public concerns on environmental issues (e.g., the need for more or less monitoring) to the attention of high-level agency decision makers. The elected officials are influenced by both the electorates they serve and various interest groups. Public Pressures and Perceptions There is no shortage of good advice on why and how to monitor. But it is frequently ignored, perhaps because public pressures often create and drive environmental monitoring efforts. In the mid-1970s, for example, controversy over proposed oil and gas development on the outer continental shelf led to extensive environmental benchmark studies as a precursor to monitoring the effects of this development. As a result of public and political concerns, Congress appropriated funds for costly programs of extensive measurements, but these programs lacked clearly stated objectives and expectations (NRC 1978~. Because of the criticisms, the benchmark studies concept was abandoned in favor of studies focused on leasing decisions. Now, some 12 years later, the Department of the Interior is returning to the problem of designing monitoring programs that address public concerns about environmental effects of the development that has ensued. As is true for most public affairs, interactions between elected o~- cials and agencies can either help or hurt monitoring activities. When elected officials' demands on agencies shift in response to shifting public and constituency group pressure, agencies often have no choice but to shift direction as well, even if their responses make little scientific or resource
28 MANAGING TROUBLED WATERS management sense. In particular, political demands may dictate the termi- nation of some programs in favor of others that are of more immediate interest or concern to the public or individual constituency groups. This situation can adversely affect the quality and usefulness of monitoring pro- grams, particularly when long-term continuous data are critical to informed decision making. On the other hand, elected officials frequently stimulate support for monitoring. Concerns raised by Maryland officials, for example, about the lack of information needed to define the extent of pollution problems or set priorities for remediation programs were influential in obtaining state and federal funding for Chesapeake Bay monitoring programs. Without visible and active political support, the scope of these programs would have been greatly reduced, and much information about the extent of pollution problems in the bay would not have been collected. Furthermore, information derived from monitoring was an important factor in obtaining agreement on remediation strategies for Chesapeake Bay. ConDicts between other societal needs and protection of the environ- ment frequently arise and compromises invariably result. Findings from monitoring programs on the extent of pollution problems, the relative risks they pose to public health and environmental resources, and the success of ongoing remediation efforts are useful to elected officials in setting bud- getary priorities and determining needs for additional legislation. Frequent reporting of monitoring findings to the public and political sectors is impor- tant in sustaining public and political interest needed to implement cleanup programs and keep them on schedule. Scientists and environmental regulatory agencies have generally been successful at informing the public and elected officials about the importance of protecting the environment as a means of safeguarding public health and welfare. For example, the public has long been aware that people are receptors for many pollutants and that serious health problems result when the waste-assimilating capacity of the environment is exceeded. Scientists and agencies, however, have not made as compelling a case about the value of monitoring in defining successful and cost-effective solutions to pollution problems or in defining environmental risks to human health. As a result, many public officials and environmental protection advocates view monitoring as a way to avoid or delay costly remedial actions rather than as a technology to help identify the most appropriate and cost-effective solutions to pollution problems. For example, the Southern California case study found that some people view the 301(h) waiver) monitoring program ~ Section 301(h) of the Clean Water Act, added in 1977 (P.L. 95-217), allows waivers from sec- ondary treatment requirements for effluent discharges into coastal waters from POTVVs when it can be shown that such discharges do not degrade water quality.
THE ROLE OF MON~O~NG IN E~IRONMENT~ ~AGEMENT 29 as a waste of money that could be used to reduce ocean waste disposal further. Indeed, this sentiment may be justified because monitoring is sometimes resorted to as an easy way out of making politically difficult decisions. The continued monitoring of acid deposition in lieu of more restrictive control of emissions in the face of overwhelming evidence of cause and effect is a frequently cited example. Public education efforts are of little help when brochures and pam- phlets are long on promotion and short on substance. Substantive monitor- ing information is rarely disseminated in a form understandable to most lay readers. Computer printouts are frequently the only documents produced. In addition, when technical reports are issued, they are written in a way that is incomprehensible to the average reader. Again experience in Chesapeake Bay is an example of how general agreement within the scientific community and the involved agencies on the need for monitoring information resulted in strong political and public support for monitoring activities. The Citizens' Monitoring Program for Chesapeake Bay, working with agencies and scientists, has been successful in educating the public and officials on the uses, limitations, and findings of monitoring program results. This program is a network of citizen volunteers who live along the bay and its tributaries. They measure selected water quality variables and routinely report their results to the Chesapeake Bay data center. Citizens who are involved in the program obtain a first- hand awareness of monitoring by taking relatively simple environmental measurements. These citizens are then able to track the success of cleanup efforts closely. They become strong advocates of monitoring activities and are conduits of information from the technical community to the general public. Failure to inform adequately and involve actively both the public and elected officials in meaningful ways is the root of many institutional problems confronting monitoring. Public and legislators' expectations about the capacity of monitoring to provide answers to important questions are often unrealistic. Monitoring program goals and decision points must be clearly stated in terms the general public can comprehend and respond to. Further, when a monitoring program is conducted or financed by dischargers or agencies that are perceived to be sympathetic to dischargers, the public is often skeptical of the results. It is important, therefore, for agencies and monitoring practitioners to inform the public and the legislators of monitoring program limitations and to exchange substantive information with interested citizens and groups openly. Governments, public utilities, and industries can afford sustained mon- itoring of only a limited number of measures of environmental quality, and they must be selected or deleted through critical analysis by experi- enced and knowledgeable people. The public is often skeptical of proposed
30 MANAGING TROUBLED WATERS changes in monitoring programs, particularly when a parameter is dropped or monitoring activities are reduced in scope. For sustained public support, it is important to convey to the public the basis for selecting and sustaining a particular monitoring program. The case studies demonstrate different degrees of monitoring program success in producing information appropriate to the needs of the groups involved. In the Chesapeake Bay Monitoring Program, for example, a good balance in the development of information products tailored to important and diverse audiences has been achieved, from managers' reports to a regular feature, "Bay Barometer," that appears in several local newspapers. In contrast, monitoring programs involving sewage discharges, stormwater runoff, and their effects on human health and living resources in the Southern California Bight have been less successful in building public awareness and confidence. Involving the public in a meaningful way must be actively pursued if support for monitoring is to be gained and maintained and monitoring re- sults are to shape public opinion. At the outset, a goal of major monitoring programs should be public participation in problem solving and definition as well as in helping the agency determine how best to face the dilemma at hand. Such active public participation is a component of the Environmen- tal Protection Agency National Estuary Program, which is now developing comprehensive management plans for 12 estuaries. Similar opportunities for public review and comment are called for in California's Ocean Plan. Once a negative attitude develops, it is difficult to change but not always so. One public information officer associated with Southern Califor- nia marine monitoring (Joseph Haworth, Jr., County Sanitation District of Los Angeles County, letter to Lisa Speer, April 1988) stated his experience: I've told the organizations and the people in contact with us on this issue that if they choose to be angry with us, it should be for what we're doing, not what they suspect we're doing. This has created an environment in which they are actually willing to listen to our information. Legal and Regulatory Influences Numerous state and federal statutes require monitoring of marine environmental parameters. Able 1.1 lists relevant federal statutes. Most coastal states have additional requirements; for example, California has more than 30 marine monitoring programs required by statute. Without statutory requirements for surveillance and monitoring, dischargers would be less likely to monitor, and agencies would have far more difficulty securing public and private funds for monitoring activities. Legal constraints also interfere with effective monitoring. Statutory
THE ROLE OF MON~O~NG IN E~RONMENT~ MANAGEMENT 31 and regulatory requirements can hinder an agency's flexibility in carrying out its monitoring requirements, lead to duplication of monitoring efforts among agencies, leave important data gaps, or commit monitoring resources to irrelevant parameters or problems that are already well understood. Examples of these problems are briefly discussed below. An example of fragmented monitoring is the existing regulatory frame- work in the Southern California Bight, where monitoring is carried out on a permit-by-permit basis. As a result, monitoring programs consider each regulated activity in isolation from all others. Pollutant loadings from non- point sources such as storm drains, urban and agricultural runoff, and the atmosphere are substantial; however, their impacts or loadings have not been monitored because the statutory mandates do not exist. Regional and cumulative impacts receive inadequate attention because individual programs are not responsible for measuring effects on larger spatial scales or from multiple sources. Monitoring parameters required by regulation or permit may become irrelevant over time, but without authority or flexibility to change monitor- ing requirements, agencies must continue monitoring required parameters. A case in point is the County Sanitation Districts of Orange County, Cal- ifornia, which are required as a permit condition to measure routinely a wide range of chemical contaminants~espite the fact that many of them are rarely if ever found in the effluent or sediments near the outfall (NRC in press>. Dropping or shifting well-founded monitoring programs as a purely political reaction to public demands is counterproductive. However, political and bureaucratic pressures that constrain agency flexibility in de- veloping and shifting programs as a reasonable response to societal needs and scientific objectives are also undesirable. Statutes and regulations often state their goals in general or vague terms, making it difficult to set criteria for determining whether the goals have been met. For example, one water quality objective of the California Ocean Plan is that "the concentration of organic materials in marine sed- iments shall not be increased to levels which would degrade marine life" (California State Water Resources Control Board 1988~. The Federal Water Pollution Control Act calls for "the protection . . . of a balanced, indigenous population of shellfish, fish, and wildlife." (See Box 2.1.) Although setting such broad goals is appropriate for legislation of a national or statewide scope and overspecification of criteria in statutes would have far worse consequences, such generalities leave the implementing agency- and the dischargers with the difficult task of defining specific criteria meaningful for use in designing monitoring programs. Establishing these criteria is of- ten contentious, involving arguments over whether they are meaningful with respect to the statutory or regulatory goal, are too prone to the influence
32 MANAGING TROUBLED WATERS BOX 2.1 STATUTORY OBJECTIVES OF MONITORING ARE OFTEN VAGUE* Federal Water Pollution Control Act Section 101(a)~3~: It is the national policy that the discharge of toxic pollutants in toxic amounts be prohibited Under Section 316(a), states may impose effluent limitations: that will assume the protection and propagation of a bal- anced, indigenous population of shellfish, fish, and wild- life.... Outer Continental Shelf Lands Act Amendments of 1978 Section 20(b) instructs the Secretary of the Interior to: monitor the human, marine and coastal environments . . . for the purpose of identifying any significant changes in the quality and productivity of such environments, for establishing trends in the areas studied and monitored.... Section 20(e) requires that: fats soon as practicable after the end of each fiscal year, the Secretary shall submit to the Congress and make available to the general public an assessment of the cumulative effect of activities conducted under this Act on the human, marine, and coastal environments. Coastal Zone Management Act Under Section 1456(a), grants are disbursed to further: the prevention, reduction or amelioration of any unavoidable loss in such states' coastal zone of any valuable environmental or recreational resource. *Italics added. Of natural factors, or are adequately sensitive measures of environmental change. Once established, the criteria, which may be based on a set con- centration of a contaminant in the environment or on biological variables, are often difficult to change. An example of the great influence of these criteria comes from the regulation of wastewater discharges off Southern California. Through mon- itoring programs, it was discovered that brittle stars (the ophiuroid Am- phioda urt;=a) are highly sensitive to the deposition of particulate wastes
THE ROLE OF MON~OMNG IN E~IRONMENT~ ~AGEMENT 33 around outfalls. Now billion-dollar decisions concerning upgrading waste treatment are being based on whether brittle stars, as representatives of a "balanced indigenous population," are found within a certain distance of an outfall. The point is not to call into question the appropriateness of this specific criterion but to highlight the public consequences of the technical interpretation of statutory or regulatory goals. Funding and Human Resources The effectiveness of monitoring is limited by the adequacy of financial and human resources available. The total financial investment for marine environmental monitoring by government, utilities, and the private sector in the United States is considerable. (See Chapter 1.) But expenditures are not well distributed among the types of monitoring (compliance, trends, and model validation), regions of the country, or the main elements of the technical implementation of monitoring (design, data collection, synthesis, interpretation, and reporting). In addition, many marine environmental monitoring programs suffer from the lack of continuity of support needed to define variability and trends or, at least, from frequent uncertainty about the continuity of support. Many of the issues concerning the distribution of financial resources are exemplified by monitoring in the Southern California Bight, the most intensively monitored coastal area in the country. Annual expenditures on marine environmental monitoring there are at least $17 million per year, most of it for compliance monitoring (NRC in press). Yet the regulators, the regulated, the public, and practitioners of monitoring are dissatisfied with the resulting collection of site-specific monitoring programs, which provides inadequate information on the overall health of the ecosystem and public health and welfare risks. No comprehensive analysis has been done to ensure the appropriate allocation of the resources committed to the most serious problems. Even if the analysis had been done, under the present regulatory structure, simple reallocation of the funds spent by wastewater treatment authorities, electrical utilities, and so on to the broader purposes of regional trends monitoring would not be possible. The Southern California case study raised another problem of resource allocation that was experienced in the other cases studied by the committee. Far too little of the available financial resources is committed to the analysis of the environmental data collected and the conversion of these data into information that is accessible and usable by decision makers. In the extreme, this situation makes the expenditures provided by taxpayers or ratepayers wasteful and, at a minimum, is frustrating to the public, regulators, and the practitioners of monitoring. It is not just money and its allocation that limit adequate and useful
34 MANAGING TROUBLED WATERS monitoring. Deficiencies in the talent and experience of the practitioners of monitoring may be at least as limiting. In addition to the need for technical specialists capable of generating high-quality chemical, biological, and physical data, effective monitoring requires individuals with broad skills and experience in experimental design; data analysis, synthesis, and interpretation; communication of results; and environmental management. Dedicated guidance by one or a few broadly trained and experienced individuals is essential to the success of monitoring programs (Strayer et al. 1986~. Such individuals are rare indeed and are virtually always the product of on-the-job training. Agency Decision Making Myth: Any good scientific study contributes to better decision making (Holling 1978~. tDiecision makers are people who, like the rest of us, are guided partly by motives that are often not so lofty and are not spelled out clearly.... There is a strong tendency in resource management to defer hard decisions as long as possible, in the hope that natural events will produce a favorable outcome. (Walters 1986) It must be understood that monitoring, even if well designed and executed, does not eliminate risks to management decisions. There is the potential of false negatives (i.e., no indication of effects when effects may be occurring in an ecosystem component not being monitored) or false positives (i.e., effects are measured but are not generally reflected in the ecosystem) (Cairns 1988~. Effective monitoring, however, may significantly reduce the uncertainty attendant upon management decisions. Federal and state resource management, regulatory, education, and research agencies are key participants in monitoring programs. The man- dates of agencies vary, but all are generally involved in protecting public health and environmental resources. Many of the agencies' mandates re- quire monitoring information. These activities include identifying threats (past and present) to public health and environmental resources, setting priorities for the use of limited resources for pollution abatement and reme- diation, developing and enforcing regulations to protect public health and environmental resources, implementing remedial programs to restore and enhance damaged resources, evaluating regulations and remedial actions, and modifying agency policy. Monitoring information, however, is but one of the elements that agen- cies consider when making environmental decisions or formulating policy. Other considerations are overriding statutory requirements and public poli- cies, economic factors (e.g., the costs of alternatives), the probability of
THE ROLE OF MON~O~NG IN E~RONMENT~ ~AGEMENT 35 understanding the problem and its causes (e.g., the chances of solving the problem using existing information), technical factors such as whether there are engineering or other solutions to a problem, legal factors such as the burden and standards of proof berg., identification of who is responsible for the problem), and the political consequences of taking action or doing nothing. In this regard, Beanlands (1988) noted six questions that a senior- level decision maker or elected public official is likely to ask when faced with any problem, including problems addressed by monitoring: 1. Exactly what is the problem? 2. Who is involved and how? 3. What are my options, including doing nothing? 4. What are my chances for solving the problem? 5. What will it cost? 6. What would you advise? The requirement to consider the institutional dimensions of technical problems means that agencies operate under constraints that can generate parallel, sometimes conflicting, objectives (i.e., to minimize expenditures, avoid controversy, foster a particular political agenda, or direct resources to issues of public concern). These constraints are often imposed by outside constituency groups, including the legislative and executive branches, reg- ulated industries, and the public. Because conflicting objectives are often settled through a political rather than scientific process, monitoring may ultimately not do what it is supposed to do: provide information for making decisions. Public demands may result in the constant shifting of monitoring activity so that useful information is never produced. Indeed, monitoring itself may be an outcome of decisions resulting from an interplay of these multiple elements. One example is the settlement on use of cooling water from the Hudson River estuary by power plants. Despite the great controversy over the likelihood and magnitude of the impact of the power plants on fish stocks in the estuary, it was clear that to avoid these impacts completely would require installation of costly cooling towers (Baslow and Logan 1982~. Instead, a compromise was reached: the eRects of larval entrainment would be monitored, and the intake of cooling water would be reduced even if it caused power shortages if these effects exceeded a given level. Monitoring, on the other hand, may be an ineffective reaction to a problem with clear causes and solutions, but for which these solutions may be costly or unpopular. When the problem of floatable materials stranding on New Jersey beaches stimulated great public concern in 1988, state and federal agencies implemented various floatable monitoring programs. Yet the source of these materials, mainly from combined sewer overflows, treat- ment plant bypassing, and solid waste handling, was identified from studies
36 MANAGING TROUBLED WATERS of similar incidents along Long Island beaches 12 years earlier (NOAA 1977; Swanson, Stanford, and O'Connor 1978~. Although expensive, a remedial program implemented earlier could have avoided the tremendous economic losses caused by the stranding of objectionable materials on the beaches; additional monitoring will do little to alleviate the problem. The fact that monitoring is frequently driven by external considerations and public pressure means that the design and conduct of a rigorously scientific investigation may not be the most limiting element of a monitoring program. This situation puts those who carry out monitoring programs in the awkward position of being "expected to practice good science in a politically motivated system" (Beanlands and Duinker 1983~. This difficult position may explain the conflict between agency and outside scientists over the validity of program design and results. Communication between the two groups is generally inadequate. In addition, agency monitoring program design and results are often not subject to objective technical review. The result is skepticism in the scientific community outside the agency. These conflicts exacerbate the problem of public acceptance of monitoring results. Fragmentation of responsibility for marine environmental monitoring within agencies (e.g., among permit writers, trends assessors, and compli- ance personnel), among agencies, and at different levels of government leads to monitoring programs with important gaps. A case in point is activity in the Southern California Bight, where incompatible monitoring techniques and reporting make it difficult if not impossible to share infor- mation, consolidate monitoring tasks, and address regional impacts in a coordinated fashion (NRC in press). Implicit in agency decision making is a clear statement of the purpose of monitoring. Criteria to guide agency decisions regarding why, when, what, and how to monitor and why, when, and what to stop monitoring as well as guidance on when and how to integrate monitoring data into decision making need to be developed. For the monitoring practitioner who has to work within this complex public policy and environmental management milieu, effectiveness may be best increased by improvements in the presentation of monitoring results to decision makers. It is generally true now that top-level decision makers rarely see monitoring results, let alone in a form that is useful to them. Translating data into information that is useful, synthesized, and relevant to the decisions that have to be made is a formidable challenge. Further, decision makers often require information from monitoring shortly after data are collected so that they can be considered in impending deci- sions. This need poses further limitations to the thorough interpretation and effective presentation of monitoring results. All three case studies found that more emphasis and resources need to be devoted to the effec- tive conversion of data into information useful to decision makers. (See Chapter 4.)
THE ROLE OF MONO IN E~RONMENT~ ~AGEMENT 37 Ten Steps to Strengthening the Role of Monitoring in Environmental Management The foregoing examples and discussion suggest that the role of moni- toring in environmental decision making can be strengthened by addressing the following areas: 1. Clear guidance is necessary on how data are to be used and what type of decisions are to be made. 2. The goals established should be achievable scientifically, techno- logically, logistically, and financially. 3. The monitoring program should be integrated into the decision- making system, with decision points and feedback loops clearly established before the data are collected. 4. Where authority and control reside should be made explicit. Fiscal controls should be compatible with program controls and objectives. 5. Channels of communication among agencies and other participating individuals and groups should be identified and efforts made to ensure that the channels are interconnected and functional. 6. The monitoring program should integrate the regulatory, data, and management needs and responsibilities of the local, state, regional and federal agencies to optimize the use of available resources. 7. Viable mechanisms should be established to involve the public and the scientific community as program participants early and often. 8. The monitoring program should include built-in mechanisms to ensure that its conclusions are communicated to decision makers and the public in terms that they can understand and act upon. 9. Monitoring programs should include mechanisms for periodic re- view and easy alteration or redirection of efforts when monitoring results or new information from other sources justifies a change. 10. The management action to be taken in response to both the ex- pected results and unexpected but possible outcomes should be identified in advance.
