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OCR for page 19
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
OCR for page 20
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.
OCR for page 21
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
OCR for page 22
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
OCR for page 23
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
OCR for page 24
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
OCR for page 25
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.
OCR for page 26
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
OCR for page 27
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
OCR for page 28
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.
OCR for page 29
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
OCR for page 30
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
OCR for page 31
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
OCR for page 32
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
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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
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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
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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
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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.)
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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.
Representative terms from entire chapter:
water quality
