4

Management

The management of a program is often as important as its technical specifications. Some of the key questions for the Biomonitoring of Environmental Status and Trends Program are whether it will be able to

  • Set priorities among issues of concern and determine where action is needed.

  • Provide information to support activities to reduce and prevent impacts of toxic substances.

  • Maintain sufficient consistency to ensure development of a useful, long-term database.

Given the effects of changing policy environments, administrative priorities, and budget constraints on the intent and effectiveness of programs like the Biomonitoring of Environmental Status and Trends Program, those questions cannot be answered with any precision. Further uncertainty arises from the large scientific and administrative scale and complexity of this program. The program's designers recognize the difficulty of developing a full-scale program design when there are so many scientific uncertainties; therefore, they have emphasized pilot and demonstration projects and other phased implementation strategies. The program components are shown in Figure 4-1.

Given the history of the Fish and Wildlife Service (FWS) in addressing toxic-substance concerns, it seems likely that problem identification on trust lands will prove to be among the more manageable components. More difficult technical, legal, and institutional problems will arise in problem identification affecting trust species not on FWS lands. There are also vexing scientific and technical problems in the design and execution of a national status-and-trends component.

Other sections of this report comment from technical perspectives on the utility of the problem-identification and status-and-trends components to achieve the three program goals.



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A Review of the Biomonitoring of Environmental Status and Trends Program: The Draft Detailed Plan 4 Management The management of a program is often as important as its technical specifications. Some of the key questions for the Biomonitoring of Environmental Status and Trends Program are whether it will be able to Set priorities among issues of concern and determine where action is needed. Provide information to support activities to reduce and prevent impacts of toxic substances. Maintain sufficient consistency to ensure development of a useful, long-term database. Given the effects of changing policy environments, administrative priorities, and budget constraints on the intent and effectiveness of programs like the Biomonitoring of Environmental Status and Trends Program, those questions cannot be answered with any precision. Further uncertainty arises from the large scientific and administrative scale and complexity of this program. The program's designers recognize the difficulty of developing a full-scale program design when there are so many scientific uncertainties; therefore, they have emphasized pilot and demonstration projects and other phased implementation strategies. The program components are shown in Figure 4-1. Given the history of the Fish and Wildlife Service (FWS) in addressing toxic-substance concerns, it seems likely that problem identification on trust lands will prove to be among the more manageable components. More difficult technical, legal, and institutional problems will arise in problem identification affecting trust species not on FWS lands. There are also vexing scientific and technical problems in the design and execution of a national status-and-trends component. Other sections of this report comment from technical perspectives on the utility of the problem-identification and status-and-trends components to achieve the three program goals.

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A Review of the Biomonitoring of Environmental Status and Trends Program: The Draft Detailed Plan Figure 4-1 Biomonitoring of Environmental Status & Trends Program components. (Source: redrawn from FWS, 1993.)

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A Review of the Biomonitoring of Environmental Status and Trends Program: The Draft Detailed Plan Management concerns are reflected in these technical assessments, and the conclusions are generally consistent with those in the preceding paragraph. Implementing of a scientifically rigorous program would probably take at least a decade to achieve; doing so in a few years would be remarkable. What follows is a brief discussion of management issues in the program and sections on administrative structure and personnel, partnerships, data management, outreach, program phasing, and cost effectiveness. Each section offers a brief evaluation of the draft detailed plan 's presentation and recommendations (FWS, 1993). Recommendations are summarized at the end of the chapter. MANAGEMENT ISSUES IN THE PROGRAM The program spans activities from local cause-effect studies to reporting on regional and national status and trends affecting national wildlife refuges, and FWS 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. 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. Thus, the program requires analysis at many levels of ecological organization from individuals to populations to ecosystems. Furthermore, monitoring of contaminant effects needs to take place over very long periods. Toxic substances that reach the environment shift constantly; time constraints require program managers to anticipate potential changes in sources and constituents and to adapt monitoring and analysis techniques to meet these changes. Finally, the data-management system incorporating all these data must be designed to serve scientific, administrative, and policy objectives. ADMINISTRATIVE STRUCTURE Key features of the administrative structure as proposed in the draft detailed plan and illustrated in Figure 4-2 are summarized below. Responsibility at the FWS directorate in Washington, D.C., has been assigned by the director to the assistant director for ecological services. Direct administrative responsibility for program development and implementation is held by the chief of the Division of Environmental Contaminants (DEC). An internal FWS steering committee for program development is led by a designee of the chief of DEC and includes regional biomonitoring coordinators and other FWS scientists and field resource managers. A series of work groups, including scientists from outside FWS, also contributed to development of the detailed plan.

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A Review of the Biomonitoring of Environmental Status and Trends Program: The Draft Detailed Plan Figure 4-2 Administrative Structure of Biomonitoring of Environmental Status and Trends Program.

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A Review of the Biomonitoring of Environmental Status and Trends Program: The Draft Detailed Plan Implementation oversight is exercised by an additional internal advisory committee composed of representatives of Regions 1-7 (field regions) and Region 8 (Washington research staff), DEC, the Division of Refuges, and the Fisheries Management Assistance Unit. The detailed plan as it evolves is to be reviewed by the advisory committee and by the National Research Council committee as discussed in this report. Data collection is to be performed by field staff trained by the Biomonitoring of Environmental Status and Trends Program and working under protocols developed by the Technical Resources Center (TRC), a core unit for technical support. The TRC is to be the focal point for development of monitoring protocols, analysis methods, and database design. Quality assurance (QA) is to be exercised through a national QA office interacting with regional QA units and guided by a program plan on policies, procedures, and documentation supported by audits on compliance with program guidance. Details of quality control (QC) are not set forth in the draft detailed plan. Roles for the TRC and Washington research staffs in QA and QC are mentioned, but administrative location is not specified. National synthesis, analysis, interpretation, and reporting of data generated by the program are headed by the Washington research unit. Regional offices are to issue periodic summaries on results of regional interest. A general strategy for program implementation is outlined in the draft detailed plan; it emphasizes training and learning through pilot projects. Personnel requirements are not specified in the detailed plan, so assessment of staffing needs, priorities, or costs was not addressed by the committee. Evaluation The draft detailed plan recognizes and promises attention to many urgent management issues. It also recognizes the need for flexibility and adaptability in response to changing contaminant problems. This program constitutes a start toward strengthening both the rationale and the information base for policies and actions to prevent and correct harm to these valued resources. Missing in the program is the administrative and budgetary context of an integrated program for reducing effects of toxic substances on trust resources. Financial and human resources are always limited. Thus, priorities need to be set among such components as national status-and-trend determinations, problem identification on trust lands, problem identification that affects trust species off trust lands, cause-effect determinations, and development of data for actions to stop discharges and mitigate damage. In the absence of a careful effort along those lines, the linkage between status-and-trend monitoring and support for on-the-ground avoidance and remedial actions could be lost or ineffective.

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A Review of the Biomonitoring of Environmental Status and Trends Program: The Draft Detailed Plan Recommendations Administrators of a program like the Biomonitoring of Environmental Status and Trends Program should develop and offer for comment to scientists and administrators, within and outside the Department of the Interior (DOI), a description and analysis, in an administrative and budgetary context, of all components of a toxic-substances program. Balance among broad-scale and site-specific information and action needs should be a focal point of analysis. The administrative and programmatic features of the Biomonitoring of Environmental Status and Trends Program should be redesigned as necessary to reflect reorganization within FWS and other DOI agencies after the establishment of the National Biological Survey (NBS). The management section of the draft detailed plan should be rewritten to reflect the new organizational setting. The plan should provide details on staffing requirements that are anticipated to meet stated objectives and discuss how those requirements will be met. Box 4-1 The Herring Gull Program as an Analogue of Partnership Design of the Biomonitoring of Environmental Status and Trends Program The Great Lakes Herring Gull Monitoring Program initiated in 1974 is an integrated program that has served many purposes over the last 20 years (Environment Canada, 1991). In many ways, the Biomonitoring of Environmental Status and Trends Program is designed similarly, but it has newer technology and protocols, some of which emerged from experience in the herring gull program. Although the herring gull program was developed for long-term monitoring, it began to incorporate more science as technology improved. In addition to recording contaminant loading in the gulls, biologists began reporting on the health of the gulls and the status of their populations. Next, they incorporated toxicological techniques, measuring the impact of chemicals on the gulls at the cellular and molecular level and combining histopathology with toxicology. Eventually, biologists identified syndromes on the basis of changes in the birds' biochemistry and physiology (using biological markers) and associated them with a suite of chemicals in the Great Lakes basin (Hoffman et al., 1987; Kubiak et al., 1989; Tillitt et al., 1992, 1993). In the late 1980s, the annual monitoring protocol of the herring gull program included both biological markers and chemical characteristics. Today, biologists are measuring trends in toxicity and trends in contaminant loading, not only in herring gulls, but in fish species as well (Environment Canada, 1991). The advantages of measuring toxicity are many. The biological tests are much cheaper and often faster than the complex procedures required to clean up and prepare samples for chemical analyses. Histopathological and biological-marker tests cost about $25, whereas a complete organohalogen chemical scan costs about $2,000. The more-expensive chemical analyses need be done only where the results of the bioassays warrant the expense. The herring gull program is analogous with the Biomonitoring of Environmental Status and Trends Program in that it has served as an umbrella to determine where the toxic leaks are in the Great Lakes system. Once the leaks were determined (such as by discovering dioxin and Mirex in the lakes) by using the herring gulls, the biologists knew where to do site-specific studies to determine the sources. Specific studies described in the peer-reviewed literature include those using Forster 's terns (Hoffman et al., 1987; Kubiak et al., 1989; Tillitt et al., 1993), double-crested cormorants (Tillitt et al., 1992), and lake trout in a number of locations around the Great Lakes (Mac and Edsall, 1991). These efforts required collaboration on the part of the Canadian Wildlife Service, FWS, the Food and Drug Administration, Michigan State University, private consulting groups, the Audubon Society, the International Joint Commission, Environment Canada, the Great Lakes Protection Fund, the Center for Inland Waters, and others.

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A Review of the Biomonitoring of Environmental Status and Trends Program: The Draft Detailed Plan PARTNERSHIPS The draft plan recognizes the need for collaboration among federal agencies, among branches of FWS, and with international institutions, state and local agencies, private environmental and scientific organizations, universities, and private research organizations. Capacity to contribute to and make use of data is the criterion for choosing partners. Data collection, documentation, management, sharing, and models are assumed to be the prime arenas for cooperation. There is much emphasis on QC and on formal agreements or contracts as the instruments for ordering relationships. Evaluation The commitment to partnerships in data collection and management appears to be genuine, and the concern for quality appropriate. The draft does not discuss in detail incentives for attracting and stabilizing partnership arrangements; presumably, agreements offering compensation in return for conformance to program protocols or access to program data would be a primary tool. The draft overlooks some promising arenas for official and unofficial partnerships with other bodies that deal with watersheds and ecosystems. Those bodies might generate data on other land and water systems that might also affect FWS trust resources. Given the critical roles of states in water quality and discharge monitoring and in fish and wildlife management generally, the benefits of partnerships with their agencies seem to be understated. Recommendations The Biomonitoring of Environmental Status and Trends Program should give explicit attention to the rationale and implementation plans for linkages and interactions with other agencies and entities. The data needed to accomplish the broad programmatic objectives will require that operationally dependable partnerships be developed. Some recommendations on this subject are provided in Chapter 2 and Chapter 3. In addition, the development of the program should include solicitation of systematic input from the NBS and other federal and state partners in the initial program design. The current steering committee of FWS personnel and the proposed advisory committee should be modified to include representatives of refuges, regional offices, the NBS leadership, and potential partners, such as other DOI agencies and non-DOI agencies, e.g., the U.S. Department of Agriculture's Forest Service and state wildlife-management agencies. Without this kind of collaborative planning, it is unlikely that the needed partnerships, cooperation, and collaboration will develop.

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A Review of the Biomonitoring of Environmental Status and Trends Program: The Draft Detailed Plan For partnerships to be effective, they need to be based on planned commitments of agency resources to coordinated action in problem identification, source identification, and impact assessment in specific settings involving mixed ownerships or programmatic jurisdictions (for instance, endangered species on public lands). Monitoring designs for problem identification, contaminant effects, and remediation followup will require continuous efforts in harmonizing protocols for all stages of information-gathering and information analysis, as well as data management and accessibility. Headquarters offices of federal agencies in Washington, D.C., will need to be assertive about partnerships in biomonitoring programs if field staffs are to be secure in committing time to cooperative, rather than agency, programs. Critical signals to encourage field-staff participation in partnerships include recognition in personnel evaluations and identification of partnership activities in annual work plans and budget submissions. There is a key opportunity for building partnerships in environmental protection and natural-resource management programs in the current movement toward integrated resource-management approaches in natural systems, especially “ecosystem management” and “watershed management.” Peer review by scientists, administrators, and those involved in contaminant issues (other federal agencies, states, private organizations, universities, and resource-use and protection groups) could decrease overlap of objectives and long-term data sets and monitoring. Case studies presented before a series of water-resource workshops sponsored by the Western Governors' Association (WGA, 1992) and National Research Council studies on water management (NRC, 1992b) demonstrate increasing satisfaction with these approaches. Pending versions of Clean Water Act amendments in both the Senate and the House of Representatives would encourage development of stakeholder-inclusive watershed organizations. Effective integration of point and nonpoint pollutants is a prime objective. The bills also specify recognition of endangered species, aquatic and riparian habitats, and species as key foci of watershed programs. Key components of ecosystem-management approaches are summarized in a 1994 report of the House of Representatives (Committee on Natural Resources, 1994). At the direction of Secretary of the Interior Bruce Babbitt, agencies of that department are exploring integrated approaches to ecosystem management. The Forest Service and other federal agencies and state governments are collaborating in diverse ways. An effective Biomonitoring of Environmental Status and Trends Program will necessarily be designed to function in these integrated approaches. Fish and wildlife advocates and administrators can expect to increase confidence in the integrity of contaminant-monitoring programs and the credibility of the urgency of remedial actions if FWS pursues its concerns in the context of multiple-agency, multiple-function forums. DATA MANAGEMENT The Environmental Contaminants Program at FWS does not have program-wide database or geographic information system (GIS) capabilities. To remedy that, a centralized database facility is proposed that will house national data from the Biomonitoring of Environmental Status and Trends Program and other data that are used in analysis, will provide database access

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A Review of the Biomonitoring of Environmental Status and Trends Program: The Draft Detailed Plan to program personnel and outside parties, and will support relatively sophisticated data queries and analyses. The draft detailed plan describes in fair detail the functional requirements of the Contaminant Information Management and Analysis System (CIMAS) that includes database hardware and software and connectivity with other federal databases and ecological information systems. Functional essentials include a user-friendly interface, selective data retrieval from distributed sources, data security, easy data input and editing, data verification, statistical analysis, and data output to electronic and printed media, project management, and system maintenance. The detailed plan sketches a process for incorporating external data that consists of data-source identification, screening, acquisition, and access. CIMAS is envisioned as providing a national clearinghouse for contaminant data not only to facilitate regional and national assessments, but also to support local field personnel and other interested parties. Evaluation The program is strongly oriented to data-gathering, with little attention to identification of users and uses or to data analysis and synthesis at any level. In addition, there is not a clear presentation of how data will flow and be used by various interested parties at local, regional, and national levels and involving various levels of synthesis and application. This sort of assessment framework should be developed and should guide data-management and project-management structures. Furthermore, there is a lack of adequate explication of formal structure for integration of laboratory and field data and for data analysis and synthesis in general, including hypothesis generation and hypothesis testing that use program and related data. The model for computing and data management might be overcentralized, depending on the program's reliance on external data. The primary data gathered by program personnel (laboratory and field measurements and observations) and the statistics and information derived from those data constitute a relatively small volume of information that could be managed with the centralized model described for CIMAS. However, incorporation and management of large GIS databases and other data sets needed for modeling and for regional and national syntheses greatly increase the size and complexity of the information system and make the centralized model impractical. Finally, there is no general data-management plan to coordinate and integrate the collection and analysis of data from the widespread network of FWS's proposed program. Data integration typically requires careful planning, much effort and goodwill, and an appropriate management structure. Without special attention to such integration, it will be difficult for the program to achieve success. The committee recommends that FWS develop a more general data-management plan to define data paths, procedures, and data manipulations. Such a plan is a critical part of the overall management of this program.

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A Review of the Biomonitoring of Environmental Status and Trends Program: The Draft Detailed Plan Recommendations Furthermore, a more-distributed model of data management might be more appropriate for the Biomonitoring of Environmental Status and Trends Program, depending on its use of and reliance on other databases. A critical component is the revisiting and reconciliation of the program computing plan with NBS initiatives. There might be a key opportunity and incentives for a division of labor between the NBS and FWS (and other management agencies). NBS leadership in encouraging compatibility in data systems should be encouraged and will prove critical both to interagency cooperation and to compatibility between national status-and-trend and agency-generated site-specific data. Given the resources that the program has now and the inadequate thought devoted to the problems involved in implementation to meet the broad goals stated in the detailed conceptual plan, the early phases of the program should concentrate on collection, storage, and analysis of program-generated data for contaminants on refuges and in trust species. That will involve method development and testing, QA and QC, data-management system development, and personnel training. The development of an effective training program to produce the needed skills in personnel will be important to program success. Later phases should build the capacity of the program to foster data integration across scales and to develop and use fully the data collection and data-sharing with other agencies and partners that are necessary to meet the broader program goals. The proposed data-management plan will help to manage the integration of data from the disparate sources and account for differences in temporal and spatial scale, data-gathering and data-processing procedures, naming and other conventions, and digital formats that will make data difficult to use. OUTREACH The detailed plan acknowledges that an educated public is necessary to generate support for such programs. Public support can also help FWS to identify and mitigate the damage from toxic substances and protect trust resources and habitats. The program's goal is to accomplish that in a manner that encourages public participation achieved through partnerships and by raising public toxic-substance awareness with state-of-the-art multimedia techniques. Internal communication is key to a well-planned information-dissemination system. Communication among branches, program managers, regional contaminant specialists, and legislative liaisons appears to be critical and appears to be implied throughout the draft detailed plan. External communication includes informing nongovernment organizations, grass-roots organizations, scientists, educators, industries, sporting and recreational groups, and state and other federal agencies. Use of the press and electronic communication is a large component of the process. Some means of doing so are listed in the draft plan. It suggests establishing an advisory board that includes FWS and public participants and using nationwide surveys to gauge the success of and to improve the program's outreach. The proposal states that scientists will be

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A Review of the Biomonitoring of Environmental Status and Trends Program: The Draft Detailed Plan encouraged to attend professional meetings and present papers at various symposia and to publish in scientific journals and special publications. The responsibility for information dissemination is to be that of an outreach coordinator “in a central facility.” General guidance for this facet of the program comes from the FWS draft manual Outreach in the Fish and Wildlife Service (Blanchard, 1992). Outreach personnel in regional and field offices will receive guidance and assistance from the existing Office of Training and Education, Office of Public Affairs, Office of Information Transfer-Refuges and Wildlife, and Office of Human Affairs. Products of dissemination will be released in the usual FWS manner. The design of a public-outreach workshop is presented in the operations manual in great detail. Information on the timing of the workshop, content, conduct, participants, materials for distribution, and possible agendas is presented. Evaluation The detailed plan presents details of a proposed outreach component in a coherent strategy. The emphasis on strengthening internal and partner communication in a technically demanding program is particularly welcome. The external-outreach component is ambitious and inclusive. The outreach component will include factual and interpretative substantive information and will also invite attention to program accomplishments and needs. It is important to distinguish those two portions of the program. The lines are regularly violated in government science and technology programs, but observing them in this program is important for protection of program integrity. Staying at the cutting edge of science is critical for successful outreach with both lay and technical audiences. Keeping abreast of science involves allocating resources to encourage technical-staff involvement in internal and external professional networks. Coordination among partners will require generous opportunities to share information and expertise. Support for late-winter and late-fall work sessions will allow field biologists and collaborators to coordinate sampling for upcoming field seasons and to share their results at the conclusion of field seasons, respectively. Cooperative sampling and testing activities should be incorporated, as should collaboration on scientific papers across agency and other institutional lines. Recommendations The outreach component of the Biomonitoring of Environmental Status and Trends Program should provide for insulation between outreach for scientific and programmatic purposes and activities focused on encouraging program support. The partnership context should include partner participation in outreach efforts, as well as technical components. The importance of toxic-substance programs and the urgency of

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A Review of the Biomonitoring of Environmental Status and Trends Program: The Draft Detailed Plan addressing them are underscored by making visible the breadth and depth of the entire network of public and private partners. PROGRAM PHASING AND DEVELOPMENT The draft detailed plan proposes a phased implementation (Chapter 8) of the program as follows: Initiate a program team and management structure. Implement a program review (including this review). Develop the Technical Resource Center. Develop a training program. Complete a pilot methods-testing phase. Complete a larger-scale demonstration phase. Implement data collection. Items 1 and 2 are completed or under way. The timetable for development of the TRC is unclear. At best, competition for positions and dollars for such a unit will be intense within FWS. Lack of clarity in overlapping roles with Region 8 (Washington research staff) might be implied by fuzziness in the draft detailed plan about organizational location of the TRC. In any event, the agency at the core of the program must make a solid commitment to nurture the TRC capable of applying the highest standard of scientific guidance ahead of the pace of program implementation. Location in the TRC of the computer-data management facility of the program is appropriate, along with the housing of scientific expertise. Training needs are to be met by the FWS training facility at Harper 's Ferry. Training will necessarily be closely linked to field experience in conduct of pilot projects as interpreted from scientific and technical, as well as operational, perspectives. The emphasis on sequencing of pilot demonstration projects of increasing complexity and scale is well placed. Priority in pilot and demonstration projects conducted by FWS should be on problem identification on FWS trust lands. Doing so is logical in view of the probable lead role of the NBS in status-and-trend determinations for biological resources at the Department of Interior and in recognition of the much more difficult scientific and technical requirements for pilot projects that address status and trends on FWS trust lands, status and trends of key trust species, or population exposure and response. The latter three elements are stated to require additional manpower, funding, and program design and, as noted in Chapter 2 and Chapter 3, might prove to be intractable in any short timeframe. Obviously, priority in a full implementation phase for FWS should also be given to problem identification on FWS trust lands.

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A Review of the Biomonitoring of Environmental Status and Trends Program: The Draft Detailed Plan Evaluation The necessity for a painful process of developing a responsible program is well understood by the authors of the draft detailed plan. However, as noted in Chapter 2 and Chapter 3 of our report, the program design and strategy are not persuasive on the feasibility of status-and-trend and trust-species exposure-and-response components. Throughout the program, the processes of program evaluation, validation, and refinement should place far more emphasis on external peer reviewers with specialized skills relevant to key program components. The TRC is crucial as a focal point for science-quality control, and its role should be more rigorously thought through and specified. The discussion of pilot-project selection is not rigorous on criteria for project selection. Recommendations The details of the TRC concept and role should be a matter for high-priority attention. Data synthesis, data-sharing, and rapid and open communication of results with a diverse constituency of scientists, managers, policy-makers, and other elements of the public will be key to the success of the Biomonitoring of Environmental Status and Trends Program. The production and use of potentially toxic chemicals are constantly changing. Thus, the breadth and technical competence represented in the TRC will be critical to the success and continuing development of a program. The TRC must in part be a clearinghouse for the latest toxicological information and must have access to and awareness of the latest information on production and use of toxic substances and on biological and ecological fates and effects of these substances. The TRC must also be in active communication with and use data generated by field personnel in the program and elsewhere. It is likely that TRC personnel will need to be active in locating or developing new biochemical or ecological markers, which also involve use of nonprogram-generated data and literature and diverse scientific expertise. Briefing papers from TRC personnel to field scientists and vice versa might be necessary. Whether or not the TRC includes analytical laboratories, it must include ready access to the data generated by those laboratories and to the technical chemical and biochemical expertise represented in them. Synthesis of results from problem-identification, cause-effect, and later status-and-trends aspects of the program also is essential to interpretation and effective application of program data and should be a high-priority endeavor of the TRC. Timely publication of program data in technical literature and active participation in professional meetings by program personnel, ranging from field scientists to TRC staff, will be essential to the kinds of data- and idea-sharing and application and interpretation of results that can make the Biomonitoring of Environmental Status and Trends Program an exceptionally useful and technically successful program. Because of the changing nature of both the contaminant problem and the technology for studying and understanding effects of contaminants, TRC personnel must have an active feedback role in design of pilot projects and standard operating procedures. This will ensure that

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A Review of the Biomonitoring of Environmental Status and Trends Program: The Draft Detailed Plan what is learned by program personnel will influence continuing development and refinement of the program. A sound rationale for pilot project selection and design is another key factor in phasing. The relative impacts of various contaminant sources are important criteria. The draft detailed plan identifies agricultural and military sources as prime common sources of toxic substances that affect wildlife and might well be included in early pilot efforts. Affected habitat types will be a factor in pilot-site selection, as will categories of affected species. The rationale should flow from stated hypotheses and supporting criteria developed through intense interaction among specialists in habitats and species, as well as in the fields peculiar to the program. The pilot projects should be extended to test methods of data integration and synthesis, hypothesis-testing and hypothesis generation and their roles in development of the program, and interaction with non-FWS agencies and other partners. COST EFFECTIVENESS The draft detailed plan says little about cost effectiveness, an important issue for Congress and DOI, which face flat or declining budgets. A well-planned and well-executed program that helps to establish status and trends in causes and consequences of toxic-substance effects on wildlife can help policy-makers and various publics to address the nature and scale of preventive and remedial programs more thoughtfully. Better protection of valued biological resources is the core benefit. Actions to protect the resources for which FWS is responsible will benefit other living resources in the pathways of toxic-substance movement, including people and other terrestrial and aquatic species and their habitats. Thus, attention to the “general health” of the land, air, and water and to natural cycles by field researchers should be an important component of the program. Early identification of potential problems will reduce costs through avoidance of postcontamination-remediation expense. Well-designed data-collection and data-interpretation strategies will prove critical in placing the burden of source and affected-site cleanup on those who generate contaminants, reducing taxpayer cost and enhancing incentives for prevention at the source. Evaluation The great attention to pilot and demonstration projects and rigorous evaluation of developmental stages will strongly support efficiency in program conduct. The Biomonitoring of Environmental Status and Trends Program was designed to be an elective program that field managers could request if so desired. It is designed to use intense activity in some geographic locations and not others. It should not be used as a mandatory program nationwide. It is important that the design of the Biomonitoring of Environmental

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A Review of the Biomonitoring of Environmental Status and Trends Program: The Draft Detailed Plan Status and Trends Program consider the prospect of waste in redundancy and the synergy of collaboration with other related biological and ecological monitoring programs. FWS has no funding specifically for the program. More funding will be required both for the NBS and for its partner organizations as the program develops. If, as seems likely, much of the earlier program and testing is done by FWS, it will need substantial funding to meet both its own needs and program-refinement objectives. Recommendations Cost effectiveness in the Biomonitoring of Environmental Status and Trends Program will be enhanced by a strong commitment to a hypothesis-driven program-design strategy. Setting priorities for program activities responsive to hypotheses about, for example, sources and classes of toxic substances that need the most urgent attention or habitat classes or species of greatest value or vulnerability will concentrate scarce resources on substantive goals. CONCLUSIONS The committee focused on six administrative and programmatic issues involving management concerns: administrative structure, partnerships, data management, outreach, program phasing, and cost effectiveness. In general, the committee found that the variables in the policy environment in which the program might be implemented, the lack of detail in the draft plan, and the lack of a strategic (as distinct from descriptive) focus make evaluative statements on management approaches extremely difficult. The learning process involved in managing such a complex program is a powerful argument for a phased approach that tests all program components, including management, on gradually increasing scales of complexity. Given the mission of the NBS, problem identification and cause-effect determinations affecting FWS trust resources might prove to be the logical focus for FWS participation in the program, with the NBS working toward systems that are compatible across jurisdictional lines and assuming a major responsibility for status-and-trend assessments. It is clear that the problem-identification component, including the multiple-lines-of-evidence approach, grows most naturally from the history of FWS contaminant efforts—both site-specific investigations and the historic early work on ducks and fish. The further development of the program should include solicitation of systematic input from the NBS and other federal and state partners in initial program design, in contrast with the current internal steering committee of FWS personnel. The process should include external peer reviewers with specialized skills beyond those available to the National Research Council committee in considering design of the TRC. The detailed-plan emphasis on partnership development is timely; however, to make this strategy worth while, implementing efforts have to

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A Review of the Biomonitoring of Environmental Status and Trends Program: The Draft Detailed Plan be innovative to go beyond the familiar and formal agreements, such as memoranda of understanding and periodic coordination meetings. As has been indicated throughout this report, the Biomonitoring of Environmental Status and Trends Program as proposed does not adequately address increasing complexities of scale. The early phases should concentrate on collection, management, and analysis of primary data collected by FWS with respect to contaminants on refuges and in trust species. Later phases should build up the capacity to foster data integration across scales and full development and use of data collection and data-sharing that involve other agencies and partners as necessary to meet the broad goals of the program. The rationale for pilot-project selection and design needs to be rigorously specified and observed. Lines of communication and information transmission need to be developed —particularly a distributed model of data management, internal and external personnel networking, data synthesis and data-sharing, rapid and open communication of results with a diverse constituency, and agency participation in forums designed to integrate resource management and protection in ecosystems and watersheds. SUMMARY OF RECOMMENDATIONS Administrative Structure Recommendation 4-1: Administrators of this kind of program should develop and offer for comment to internal and external scientists and managers a description and analysis, in an administrative and budgetary context, of all components of a toxic-substances program. Recommendation 4-2: The administrative and programmatic features of this program must be collaboratively redesigned to reflect reorganization within FWS and other DOI agencies, and the establishment of the NBS. Recommendation 4-3: A human-resources evaluation should be conducted to clarify the range and magnitude of skills needed and to support phased training and recruitment strategies. Partnerships Recommendation 4-4: Strong partnerships with other federal agencies, state agencies, universities, research institutions, and other appropriate organizations should be established to link scientific competence and its application in a cohesive sustained effort. Models for effective collaboration should be developed and tested in pilot studies.

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A Review of the Biomonitoring of Environmental Status and Trends Program: The Draft Detailed Plan Data Management Recommendation 4-5: A data-management plan needs to be developed that establishes a general framework and guidelines for data collection, transfer, exchange, and dissemination. Recommendation 4-6: A distributed model for data management should be developed that provides linkages to existing relevant databases, rather than attempting to centralize all needed data. Recommendation 4-7: The computing plan should be revisited and reconciled with new NBS initiatives. Recommendation 4-8: Monitoring design should be continually reviewed so that information-gathering and information analysis are harmonized. Recommendation 4-9: Initial efforts should be concentrated on collection, storage, and analysis of program-generated data on contaminants on refuges and in trust species. Outreach Recommendation 4-10: Field staffs concerned with toxic-substance effects should be encouraged to participate in forums established to seek integration of government and private natural-resource management of such regions as watersheds and ecosystems. Program Phasing and Development Recommendation 4-11: The role and specifications of the TRC should be carefully coordinated with the developing needs of the program. Recommendation 4-12: Pilot projects should be extended to test methods of data integration and synthesis. Cost Effectiveness Recommendation 4-13: There should be a strong commitment to a hypothesis-driven program-design strategy so that the cost effectiveness of the program is enhanced.