5

Conclusions

After reviewing the program's detailed plan, this committee concludes that the U.S. Fish and Wildlife Service (FWS) Biomonitoring of Environmental Status and Trends Program has involved scientific review and analysis in its program planning and constitutes an advance in program development. There is a need for this kind of program to evaluate the presence and impact of contaminants that potentially affect the nation's trust lands and species.

However, a great deal of work remains to be done before implementation if the program is to be a success. The Fish and Wildlife Service should begin its revision of the program's detailed plan by starting with the fundamentals. It can do this by asking itself the following questions:

  • What specific question do we expect this monitoring to answer? (I.e., rather than focusing on nonspecific terms, such as “status and trends, ” what answer will actually drive a contemplated decision?)

  • What budget are we considering allocating to this monitoring?

  • Does the monitoring address a question that justifies this budget?

  • Why do we think that the monitoring will be capable of delivering a convincing answer to the question?

  • Why do we think that the monitoring is an efficient way to answer this question?

The program should be far more hypothesis-driven and more responsive to clearly stated questions than is indicated in the detailed plan. That is true for all the components reviewed: problem identification, status-and-trends analysis, causality analysis, and management decision-making.

In an ideal world, monitoring programs would always be based on clearly stated hypotheses. The committee, however, understands that not all problems are necessarily amenable to expression in such a formal way. Thus, by “hypothesis-driven,” the committee does not mean that the program should be a laboratory exercise. Rather, FWS needs to design the program and



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OCR for page 65
A Review of the Biomonitoring of Environmental Status and Trends Program: The Draft Detailed Plan 5 Conclusions After reviewing the program's detailed plan, this committee concludes that the U.S. Fish and Wildlife Service (FWS) Biomonitoring of Environmental Status and Trends Program has involved scientific review and analysis in its program planning and constitutes an advance in program development. There is a need for this kind of program to evaluate the presence and impact of contaminants that potentially affect the nation's trust lands and species. However, a great deal of work remains to be done before implementation if the program is to be a success. The Fish and Wildlife Service should begin its revision of the program's detailed plan by starting with the fundamentals. It can do this by asking itself the following questions: What specific question do we expect this monitoring to answer? (I.e., rather than focusing on nonspecific terms, such as “status and trends, ” what answer will actually drive a contemplated decision?) What budget are we considering allocating to this monitoring? Does the monitoring address a question that justifies this budget? Why do we think that the monitoring will be capable of delivering a convincing answer to the question? Why do we think that the monitoring is an efficient way to answer this question? The program should be far more hypothesis-driven and more responsive to clearly stated questions than is indicated in the detailed plan. That is true for all the components reviewed: problem identification, status-and-trends analysis, causality analysis, and management decision-making. In an ideal world, monitoring programs would always be based on clearly stated hypotheses. The committee, however, understands that not all problems are necessarily amenable to expression in such a formal way. Thus, by “hypothesis-driven,” the committee does not mean that the program should be a laboratory exercise. Rather, FWS needs to design the program and

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A Review of the Biomonitoring of Environmental Status and Trends Program: The Draft Detailed Plan plan for the interpretation of data in the light of the need to ask relevant questions, eliminate unlikely answers, and use the most likely answers as a basis for further investigation. By reviewing the fundamental nature of the program and its need to be hypothesis-driven, FWS should be able to evaluate the program 's ability to distinguish genuine ecological change from background fluctuation, to assign ecological change to a specific cause, and to distinguish and evaluate the impacts of contaminants and other causes of detrimental ecological changes, and it should be able to evaluate the ability of monitoring and the other suggested techniques, such as “weight of evidence” and “ecological health indicators,” to provide the answers to its questions. Additional key themes in the report include the need for A phased approach to implementation with initial emphasis on problem identification on FWS trust lands. Pilot studies and methods-testing, especially in defining ecological action levels. Outreach and especially partnerships with other federal agencies involved in contaminant assessment and monitoring and with state and local government agencies. Thus, a revision of the detailed plan keeping the key concept of fundamentals and hypothesis-testing in mind, as well as the other recommendations in this report, will lead to the development of a scientifically defensible program that will provide the answers that FWS needs to make its decisions appropriately. In the case of problem identification and status-and-trends analysis, hypothesis-testing means that the program should have the ability to conduct short-term diagnosis rapidly with incomplete evidence and to conduct long-term modeling where current data can be collected in such a way that long-term future problems can be predicted and prevented. For causality, a fundamental step is to evaluate the likelihood that toxic substances are the cause of an effect, measure the relevant ecological characteristics, and determine how much of an observed effect can be attributed to toxic substances, as opposed to other natural and human causes. Clear statements about analysis pathways, decision criteria, rules of evidence, and methods of drawing inferences are also necessary if this program is to be successful. A classic failing of monitoring programs is a lack of attention to such issues until after data have been collected. Program designers should specify beforehand, as explicitly as possible, how raw data will be turned into usable information. That will allow FWS to ensure that it is able to make its own and its partners' current and future monitoring data available. The process that the committee recommends to implement this inference-based procedure is ecological risk assessment. By undertaking the use of ecological risk assessment, FWS would improve its problem formulation, analysis, risk characterization, verification and monitoring, and uncertainty assessment. The result will provide information on the nature, magnitude, extent, and likelihood of effects that can be used by refuge or resource managers in making environmental-management decisions, e.g., on such matters as the environmental benefits of remediation and restriction of use of a chemical. In the case of management, the results of deductive inference are needed to set program priorities and to make decisions regarding program support and prevention and intervention

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A Review of the Biomonitoring of Environmental Status and Trends Program: The Draft Detailed Plan activities. A data-management plan is a critical part of the overall management of this program. There is a clear distinction between a database system, made up of hardware and software, and a data-management plan, which defines data paths, procedures, responsibilities, and data manipulations. The program proposes to coordinate and integrate the collection and analysis of data from a wide network of practitioners —its partners in the program. Such an activity has no chance of succeeding without a data-management plan that is as fully developed as the data-gathering plan itself. In conclusion, the committee believes that because the detailed plan of the program does not sufficiently address the issues of problem identification, causality, and management and the linkages among these three elements, the Biomonitoring of Environmental Status and Trends Program will be unable to satisfy the three goals that it indicates that it wants to achieve: 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.