A Review of the Biomonitoring of Environmental Status and Trends Program: The Draft Detailed Program (1995)

Over 7 billion pounds of toxic chemicals are released into the air, land, and water of the United States each year (EPA, 1987), and more than half the U.S. national wildlife refuges are thought to be affected by these contaminants (INEL, 1990). In response to concerns expressed by the public, Congress, some agencies, and scientists, the U.S. Fish and Wildlife Service (FWS) undertook to develop a comprehensive program for the assessment and monitoring of potentially toxic substances on the trust resources⁷ for which it is responsible: the Biomonitoring of Environmental Status and Trends Program.

FWS, although it has statutory authority to answer such questions, found that it could not, because it lacked adequate information. FWS monitoring resources are focused on monitoring metals in fish and waterfowl; pesticide contamination poses a large threat to numerous species groups, but is largely unmonitored. In an initial survey, FWS identified 78 issues involving contaminants that potentially affect its trust resources (see Appendix B). The most common source is agriculture, and the most threatening contaminants appear to be organic chemicals (including pesticides), nitrogen, phosphorus, lead, mercury, cadmium, and chromium. FWS then decided that a program should be initiated to assess these issues. That program, the Biomonitoring of Environmental Status and Trends Program, is now part of the Department of the Interior (DOI) National Biological Survey (NBS).

At the request of FWS and then the NBS, the National Research Council formed the Committee to Review the Department of the Interior's Biomonitoring of Environmental Status and Trends Program. This report constitutes the first phase of the committee's output. Its purpose is to evaluate the concept of the program as outlined in Biomonitoring of Environmental Status and Trends Draft Detailed Plan (known hereafter as the “detailed plan”). The remainder

of this chapter describes the program, describes related federal agency efforts, and provides an overview of the Research Council study.

This section provides some background on the program. The information has been gathered from a variety of documents provided to the committee by the NBS and FWS.

Biomonitoring programs are scattered throughout the federal government (e.g., the Environmental Monitoring and Assessment Program, EMAP, at the Environmental Protection Agency); however, the Biomonitoring of Environmental Status and Trends Program would be the only monitoring program that addresses contaminant impacts on FWS trust resources. Its purpose is to adopt a comprehensive ecosystem approach⁸ to identifying contaminant problems. When fully operational, the program is to identify the location of contaminant-related ecosystem degradation and provide answers to such common contaminant-related questions as the following (FWS, 1993):

• What are the major contaminant threats to FWS trust resources?

• Are contaminant impacts to trust resources increasing or decreasing?

• Which trust resources are degrading or improving on a national, regional, and local level?

• What contaminants impact national wildlife refuges and what are the probable contaminant sources and pathways?

The program consists of four sampling networks as shown in Figure 1-1: (1) problem identification on trust lands, (2) status⁹ and trends¹⁰ on trust lands, (3) population exposure and response of key trust species,¹¹ and (4) status and trends of the habitats of key trust species.

The Biomonitoring of Environmental Status and Trends Program has three goals as noted in the detailed plan (FWS, 1993):

Goal 1: Determine the status and trends of environmental contaminants and their effects on trust resources

Goal 2: Identify and assess the major factors (relative to Goal 1) affecting trust resources and provide current and predictive information to alleviate impacts

Goal 3: Provide summary information in a timely manner to managers and the public to guide conservation efforts.

In its detailed plan, FWS outlined how it expects to achieve its goals. Because the questions are broad, multiple lines of evidence are required to address the status and trends of contaminant impacts on trust resources.

To meet Goal 1, monitoring will be based on analytical chemistry, bioassays and toxicity tests, biological markers, and population-and community-level indicators. No single method or type of method can be used to measure the presence of, exposure to, and effect of the wide variety of contaminants potentially affecting trust resources. Analytical chemistry measures the concentration of various contaminants. Bioassays and toxicity tests provide direct evidence of contaminant effects on the survival, growth, behavior, and reproduction of aquatic and terrestrial organisms. Biological markers and indicators of organism health can indicate exposure to and effect of general classes of contaminants or specific contaminants. Indexes of community structure and function reflect changes in species composition and relative abundance.

The program's data-collection approach has been designed around two major components: FWS trust lands and trust species (anadromous fish, migratory birds, some marine mammals, and federally listed endangered species). For the FWS trust lands, two sampling approaches have been developed —one to identify specific contaminant problems and the other to measure the status and trends of contaminants. For the trust species, indicator or surrogate species will be used to support two sampling designs focusing on trust-species exposure and response and on status and trends of habitat condition. All data will be subject to a quality-control and quality-assurance program.

To meet Goal 2, the Biomonitoring of Environmental Status and Trends Program will use a modern database-management system to organize, store, and retrieve internal and external information. The information will be used to assess current effects and predict potential effects on fish and wildlife. A research component will identify new or emerging problems and provide new data-collection and data-interpretation methods.

To meet Goal 3, the Biomonitoring of Environmental Status and Trends Program will present the information developed in meeting Goal 2 in an aggressive outreach effort to natural-resource managers, decision-makers, and the public.

• Draft detailed plan (completed 1993).

• National Research Council committee review.

• Pilot testing of refuge-monitoring strategy and bioassessment techniques (FY 1993-1995).

• Development or adoption of data-management system (started in FY 1994).

• Demonstration testing of the Biomonitoring of Environmental Status and Trends Program concept on subset of sites (FY 1995-1997).

• Full implementation (FY 2000).

The Idaho National Engineering Laboratory (INEL) conducted an evaluation to determine what 15 federal agencies were mandated to do and were doing about monitoring the environment (Olson and Breckenridge, 1990). Through literature searches, telephone interviews, and mail-in surveys, the researchers identified more than 300 environmental monitoring activities. Of those, fewer than 30 focused on issues with a regional or national perspective; the rest were aimed at local concerns. Several could complement FWS's future monitoring efforts. These include the following:

• The National Oceanic and Atmospheric Administration (NOAA) National Status and Trends Program makes multimedia assessments in coastal areas and larger U.S. estuaries.

• The U.S. Geological Survey National Stream Quality Accounting Network and National Water Quality Assessment Program (in pilot phase at that time) assess water quality and trends.

• EPA's EMAP is designed to monitor status and trends in the conditions of ecological resources nationally, regionally, and on the subregional scale.

• The National Acid Precipitation Assessment Program (NAPAP) focuses on site-specific impacts on soils.

• The Natural Resources Conservation Service (formerly the Soil Conservation Service) has data on physical and chemical properties of many soils.

• Additional assessments by DOI's Bureau of Reclamation, Minerals Management Service, Bureau of Land Management, and the U.S. Department of Agriculture's Forest Service could also provide information primarily on habitat inventories.

• State programs vary according to state needs.

• The National Park Service (NPS), NOAA, and EPA have air-monitoring programs, but coordination is limited. The NPS program is likely to be the most useful; it examines the effects of air pollution on a wide range of plant species in more than 65 parks nationwide.

According to INEL, few of the programs could help FWS to assess the health of fish and wildlife directly; NOAA's National Status and Trends Program is an exception. And none

except the existing National Contaminant Biomonitoring Program (NCBP) already in FWS attempts to address contaminant conditions in terrestrial animals, migratory waterfowl, and fish.

In some aspects of its goals and design, the Biomonitoring of Environmental Status and Trends Program resembles some other broad-based monitoring programs, in particular EPA's Environmental Monitoring and Assessment Program. It shares difficulties and challenges with EMAP as well. Those difficulties and challenges include handling cause-effect relationships, data management, ability to detect trends, indicator development, framing of hypotheses, and obtaining sufficient resources to implement the program (NRC, 1992a, 1994a, 1994b). Questions also remain about the value and costs of these programs.

The mission of FWS is to “conserve, protect and enhance fish and wildlife and their habitats for the continuing benefit of people” (FWS, 1993). To assist FWS, programs were developed and implemented with the explicit goal of identifying and assessing toxic-substance effects on trust resources. In the FWS Division of Environmental Contaminants, for example, FWS attempts to identify, assess, prevent, and eliminate exposure of fish and wildlife and their habitat to toxic substances and, if necessary, restore injured or damaged trust resources. This section describes FWS's history in identifying and alleviating threats to its trust resources.

Pesticides with potential adverse effects on nontarget resources and wildlife are produced and used in the United States and elsewhere, and this presents problems and challenges for monitoring and evaluation. As mentioned earlier, 7 billion pounds of toxic chemicals are released in the United States each year, and more than half the U.S. national wildlife refuges are thought to be affected by them.

Pesticides and herbicides, heavy metals, and atmospheric pollutants from distant sources are not the only substances that require monitoring in birds and other wildlife. There is increasing evidence that trace-element contamination associated with agricultural drainwater in the western United States is affecting wildlife. Such elements are said to be responsible for the widely publicized wildlife deaths and deformities at Kesterson National Wildlife Refuge in California; these suggestions accentuate the need for FWS to have a mechanism to evaluate potential toxic-substance threats to trust resources (Ohlendorf et al., 1989).

A 1986 FWS report, Preliminary Survey of Contaminant Issues of Concern on National Wildlife Refuges, includes a proposed national list of contaminant issues that require management attention. It summarizes responses to a questionnaire sent to each refuge field station. Respondents were asked to identify contaminant “issues” that seemed to be having persistent adverse impacts on refuge habitats, animal populations, or human health and safety or

that potentially violated federal or state laws, local ordinances, or international treaties. Identified contaminant “issues” were put into four categories:

Category A: Evidence indicates the need for corrective action.

Category B: On-site direct evidence indicates the need for in-depth monitoring and analysis of impacts.

Category C: On-site or off-site circumstantial evidence indicates a priority need for additional reconnaissance monitoring.

Category D: Current evidence does not justify characterization as a contaminant issue.

A list of the 78 categorized contaminant issues of concern on 85 refuges is in Appendix B.

Most of the contaminants were associated with agricultural, industrial, or municipal activity originating off the refuge site in a point source (e.g., a sewage-treatment plant) or a nonpoint source (e.g., agricultural drainage) and were transported to aquatic refuge environments through natural and developed water-delivery systems. According to the report, the relationship to aquatic ecosystems is generally predictable on the basis of management objectives and physical features of many refuges. For the nine issues in Category A and the 35 in Category B, some form of study or planning was under way.

In a presentation before the Research Council committee on May 19, 1994, Pamela Matthes, acting assistant director for ecological services of FWS, reviewed toxic-substance problems on FWS trust resources. FWS trust responsibilities extend over the 91 million acres of National Wildlife Refuge System lands. Matthes reported that the number of wildlife refuges with toxic-substance problems is increasing; about 350 refuges of the total of 499 have documented or suspected toxic-substance problems. Forty-five refuges have fish-consumption advisories. Only 13 of the refuges investigated reported having no toxic-substance problems. Toxic-substance threats to trust resources include Superfund-site conditions, oil and chemical spills, permitted discharges, pesticides, and the presence of trace elements in soil. Matthes reported that FWS had documented many impacts on wildlife on its refuges: deaths, deformities, reproductive impairments, altered behavior, biochemical alterations, immune-response depression, and even a general reduction in biodiversity of wildlife. As a result of these findings, FWS had identified the immediate need to focus assessment of refuge contamination on the evaluation of the magnitude of impacts of toxic substances on trust resources.

FWS has a substantial history in identifying threats to trust resources and providing data that lead to reduction or banning of chemicals that are adversely affecting those resources. FWS's Patuxent Wildlife Research Center Service began to study the impact of organochlorine pesticides on birds and other nontarget organisms in the mid-1940s. By 1962, with the publication of Silent Spring by Rachel Carson, the seriousness of the pesticide impacts on nontarget organisms, especially birds, was being documented. Continued documentation of the widespread impact of organochlorine pesticides on birds and other organisms eventually led to

the restricted use of DDT in 1972 and the later removal or reduction in use of other organochlorine chemicals used in the United States.

During 1965-1990, FWS implemented the National Contaminant Biomonitoring Program. The NCBP collected data on species-specific chemical residues (e.g., pesticides, PCBs, and metals in fish, starlings, and waterfowl). FWS also participated in the National Pesticide Monitoring Program, a multiagency effort in the mid-1960s to evaluate environmental concentrations of persistent organo-chlorine pesticides. FWS established and operated networks for sampling contaminants in songbirds, waterfowl, and freshwater fish and was the only agency that continued to collect data into the 1980s. The program documented trends in organochlorine pesticides that had accumulated in several species of birds throughout the United States. Several general “hot spot” areas for specific compounds were identified, such as increased concentrations of DDT in the southwestern United States and of PCBs in the Great Lakes region. The concentrations of pesticides in the environment and frequencies of occurrence of these chemicals were established, and the information was used to develop environmental regulations for organochlorine chemicals. However, FWS discontinued the avian toxic-substance monitoring program in 1989.

A survey of system-wide resource problems was conducted during 1981-1982. The survey collected data on fish hatcheries, research centers, and water-quality problems. It identified resource-management problems through the perceptions of field personnel. Little followup or remediation was based on the survey's findings.

In the early 1980s, FWS derived a habitat-assessment method—Habitat Evaluation Procedures (HEP). The method used a series of habitat-suitability index models to assess the relative value of various types of habitat for fish and wildlife.

In 1987, Congress appropriated funds for INEL to develop a scientifically sound national strategy and plan for reviewing and integrating activities and responsibilities of all federal agencies relative to contaminant monitoring in ecosystems. The plan had several tasks, of which the first focused on refuge-specific monitoring for the National Wildlife Refuge System.

Also in 1987, the General Accounting Office (GAO) issued a report entitled National Refuge Contamination Is Difficult To Confirm and Clean Up (GAO, 1987), which indicated that the current survey method (questionnaires) did not identify all contaminant problems. Obstacles noted by GAO in identifying and cleaning up contaminants included: “(1) a lack of funding, water quality criteria, and regulatory authority and (2) the lengthy process involved in identifying the parties responsible for the contaminants.”

In 1990, the National Wildlife Refuge System was audited by DOI's inspector general. The findings were highly critical of FWS's record, and the following shortcomings were noted (DOI, 1990):

• Lack of national program goals and long-range program for detecting contaminants or correcting contamination on refuges.

• Lack of a “reactionary posture” (assumed to mean a timely response) when contaminant problems are detected.

• Lack of problem resolution when contaminant problems on refuges are corrected.

• Lack of implementation of INEL plans and procedures.

Overall, the program focused primarily on the presence of contaminants, and insufficient information was provided to managers to develop and make decisions about alternative action plans.

The National Pesticide Monitoring Program depended exclusively on tissue-residue data. The organophosphate and carbamate pesticides generally do not accumulate in tissues. Therefore, the program was limited to addressing exposure of wildlife to organochlorine chemicals and did not evaluate the biological effects of the organophosphate and carbamate pesticides. Since originally proposed, the program has evolved to include chemicals that do not accumulate in the tissues (and thus are not detectable by tissue-residue analysis) but are still toxic. Furthermore, FWS has decided to revise and expand its toxic-substance monitoring programs to address toxic-substance issues that affect all FWS trust resources. FWS proposed that more extensive geographic coverage and a suite of bioassessment methods be incorporated into the revised program.

The Biomonitoring of Environmental Status and Trends Program was designed solely to improve the scope and quality of the needs of FWS managers in relation to contaminants. Traditionally, the NCBP measured only the concentrations of chemicals in biological tissue. In response to recent advances in toxicity-testing, the program was designed to measure changes both in biochemical and toxicological responses in animals and in contaminant-trend data that might reveal possible hot spots for more detailed investigation. This will be accomplished by identifying reference areas and reference resources that need further attention. The approach is designed to be active, as well as reactive. The program has never been put to use by FWS; therefore, its practicality has never been tested.

The program as conceived spans activities from local cause-effect studies to reporting on regional and national status and trends affecting national wildlife refuges and trust species on or off trust lands. The refuge system and trust species and habitats encompass a diverse and rich variety of physical and biological settings, species, and ecosystem types.

As envisioned, the program is further complicated by diversity in sources and transport media for toxic substances, by the fact that most substances affecting habitats and species of

concern to FWS originate off its trust lands, by the exposure of migratory species to widely dispersed habitats, and by the movement of all but the most site-bound species through ownership boundaries.

The program requires analysis at many levels of ecological organization from individuals to populations to ecosystems. Potential applications of information are also diverse, ranging from status-and-trends determinations to problem identification at specific sites and to cause-effect linkages on various scales for purposes ranging from legal actions to enjoin contamination to the setting of priorities for remediation. Users are similarly diverse, ranging from refuge managers and contaminant specialists to regulatory personnel, agency administrators, and policy-makers.

Monitoring of contaminant effects needs to take place over many years, because some substances are persistent and can induce effects over the long term. Many toxic effects are difficult to detect and might be manifested as reduced growth and reproduction, as opposed to death or morbidity. Recognition of these effects might be more likely when data are viewed across longer periods and larger geographic areas; this places special importance on partnerships in data collection, management, interpretation, and sharing. Long-term monitoring imposes special requirements, such as continuity in sampling design and measurements, quality assessment and quality control in diverse situations, continuity of funding, and rigorous archiving.

Toxic substances that reach the environment shift constantly, and this requires program managers to anticipate potential changes in sources and constituents and to adapt monitoring and analysis techniques to meet these changes.

The data-management system must be designed to serve multiple objectives. To foster their effective use in data analysis and synthesis at levels from specific sites to policy-making, data must be well documented, user-friendly, readily accessible via networks, and readily integratable with other sources of information.

On the basis of the 1986 FWS issue paper, an FWS steering committee wrote a conceptual plan for the Biomonitoring of Environmental Status and Trends Program in 1990, which was released in 1991. Another steering committee of FWS staff then wrote the detailed plan (whose review is the subject of this study).

Since the National Research Council was commissioned to do this study by FWS, a change in administrations has occurred. The secretary of the interior has formed the National Biological Survey to focus all research and monitoring activities in DOI in a new agency (although some activities remain within FWS). The NBS inherited the lead in developing the Biomonitoring of Environmental Status and Trends Program. The Research Council has written a report, A Biological Survey for the Nation (NRC, 1993), that provides recommendations to the secretary on the formation of the NBS.

That report proposed a research agenda for the NBS that was far broader than the existing research effort in DOI but was also focused and had priorities according to likely immediate and long-term user needs. A National Biotic Resources Information System was envisioned to make

reliable biological information more accessible to diverse users. The report also described how the many public and private entities involved in current research on biological resources could work together in a new entity called the National Partnership for Biological Survey to provide comprehensive information that would be useful for decision-makers at all levels of government and outside government. The recommendations of the Research Council NBS report, if followed, should, according to the committee, provide the United States with a framework for making decisions about the management, use, and protection of its biological resources.

In response to the request to evaluate the Biomonitoring of Environmental Status and Trends Program, the committee excerpted five questions from its overall charge (see Appendix A) as a basis for its report:

1. Will the program be able to identify current and future problematic trends on and threats to FWS lands and trust species on national and regional scales in a useful and timely manner?

2. Will the program be able to identify causes (including identification of pathways and sources) of observed changes (trends and threats) to trust resources, whether they are human causes or natural fluctuations?

3. Will the program be able to rank issues of concern and determine where action is needed?

4. Will the program provide information to support activities to reduce and prevent contamination impacts?

5. Will the program maintain sufficient consistency to ensure development of a useful, long-term database?

In undertaking this task, the committee focused its review on the draft detailed plan (FWS, 1993) and the operations manual as originally written by INEL (Olson and Breckenridge, 1990).¹² References made throughout the reminder of the text are to these two documents.