Group 6:
Kristeena DiPasquale
Ben Kriete
Nathan Olsson
Becca Pacheco
Josy Raycroft
A Critique of “A Call to Action,”
CCMP for the Mobile Bay National
Estuary Program
1.0 Plan Summary
1.1 Project
Area
1.2 Key
Issues
1.3 Goals,
Objectives, and Management Plans
2.0 Plan Critique
2.1 Sustainability
2.2 Ecological
Integrity
2.3 Adaptive
Management
2.4 Human
Aspects
2.5 Legislative
Aspects
3.0 Conclusions
[NB: All unoriginal material is this document is drawn from the Mobile Bay NEP CCMP Volumes I and II.]
1.0 Plan Summary
“The mission of any National Estuary Plan – and of the Mobile Bay Plan in particular – is to establish and oversee a process for improving and protecting the Estuary’s water quality, while also maintaining the integrity of the whole system – its chemical, physical, and biological properties, as well as its economic, recreational, and aesthetic values.”
-- Volume I, page 2 Comprehensive Conservation and Management Plan
Congress established the National Estuary Project in 1987 to provide guidelines for a planning process to protect estuaries of national scope or importance that are threatened by pollution, development, or overuse. The NEP sets up guidelines for establishing a consensus-based formula for researching and developing a plan of action. Consensus is particularly important because the councils establishing the plans have no regulatory authority, meaning that compliance is entirely voluntary.
1.1 Project Area
The Mobile Bay Estuary is the transition zone between the Mobile Bay watershed and the Gulf of Mexico. The watershed covers two thirds of the state of Alabama, and portions of the states of Tennessee, Georgia, and Mississippi. Flowing 62,000 cubic feet per second, it is the fourth largest watershed in the U.S. in terms of volume, and the sixth largest river system, covering 43,662 square miles. For political reasons, the Mobile Bay NEP project limited its focus to those parts of the system that are within Alabama. The Bay itself averages only ten feet deep, is 32 miles North to South, and between 10 and 23 miles wide. It receives an average of 4.85 million metric tons of sediment annually. Salinity is highly variable, based on tides, currents and rainfall. Rainfall averages 65 inches annually. Average summer temperatures range between 80 and 100 degrees, with temperatures below freezing common in the winter.
Human uses range from industrial manufacturing to recreational boating, fishing, and vacationing. Agriculture is another activity in the watershed with important management implications. Population and development are both increasing, bringing both opportunities and perils.
1.2 Key Issues
The Mobile Bay Estuary is an aquatic system, and as such the most important issues revolve around water quality. Sedimentation and nutrient-loading from agriculture is another area of concern, as is disruption of natural flow regimes by dams, bridges, levees, and other impediments. Pathogens from sewer outflow, foreign and domestic shipping, and flooding of agricultural fields are also an important concern regarding the central value of water quality. Tangent to this central issue are related issues, including increasing recreational use, which results in damage to important submerged aquatic vegetation (SAV) habitat and disruption of other sensitive habitat types, such as nesting areas for migratory and colonial birds. Development for commercial, residential, and transportation purposes is another subject of alarm. Development leads to degradation of habitat in general through exacerbating problems with sedimentation and run-off related issues due to an increase in impervious surface. Human activity can also be disruptive in a variety of ways; noise disrupt nesting birds, pesticides harm aquatic invertebrates, pets kill wild animals, and roads and recreational trails contribute to habitat fragmentation. Directly, habitat is removed as it is built over. These are all issues obvious to trained ecologists and biologists; the Mobile Bay NEP planners also solicited input from a Citizens Advisory Committee, with the results seen in Chart 1. Though a professional habitat manager might rank these issues differently than the Advisory Committee, they still provide valuable insight into the wishes and beliefs of laypeople.
1.3 Goals,
Objectives, Management Plans
Throughout the CCMP, the MBNEP determines issues
of concern, and then distills management actions for those issues into objectives.
Objectives are intended to deal with key issues raised in the planning
process in a general sense and provide a general cognitive framework for planning
work, while a step lower in the hierarchy, sub-objectives provide actions
to be taken and goals to be met more immediately.
A list of these objectives and sub-objectives is found in Table I.
|
Table I: A list
of objectives and sub-objectives of the Mobile Bay NEP Commission (drawn
from Volume I of the CCMP) |
|
|
Objective |
Description |
|
Water Quality |
Water Quality Objective:
Attain and/or
maintain water quality sufficient to support healthy aquatic communities
and designated human uses by 2010. |
|
Sub-objective I:
Develop allowable water quality-based
loadings sufficient to maintain water quality |
|
|
Sub-objective II: Reduce nutrient loads in identified,
problem sub-basins by 2006, with increased management of both nonpoint
and point source nutrient loads in other Mobile Bay NEP sub-basins or
from the Mobile River drainage basin as a whole (by supporting efforts
of others with jurisdictional authority), until levels are established
based on allowable loadings or total maximum daily loads. |
|
|
Sub-objective III:
Minimize introduction of pathogens sufficient to protect public health
from in-port ship ballast exchange, marine waste from commercial and
recreational vessels, sewage system failures, point source discharges,
stormwater/nonpoint source discharges and other sources by 2010. |
|
|
Sub-objective IV: Evaluate the sources and loads of
toxic chemicals to Mobile Bay NEP area waters by 2003, and reduce, if
necessary, such discharges to meet applicable water quality levels by
2010. |
|
|
Living Resources |
Living Resources
Objective: Maintain
native populations within historical ranges and natural habitat and
restore natural populations that have declined. |
|
Sub-objective I: Gather the information necessary
for the conservation of economically and/or ecologically important species,
including threatened and endangered species (within the Mobile Bay NEP
area) by analyzing 75% of relevant, available data sets by 2003 and
by continued monitoring and assessment. |
|
|
Sub-objective II: Prevent, where possible, the introduction
of non-native species into native environments; manage, as necessary,
the introduction of non-native species used in conservation management
programs under controlled circumstances; control/reduce known nuisance
and/or introduced species; and gather information on unknowns by 2003. |
|
|
Sub-objective III:
Maintain and/or increase, if feasible, within natural variance, present
catch levels of commercial and recreational fisheries resources. |
|
|
Habitat Management |
Habitat Management
Objective: Provide optimum fish and wildlife habitat in the Mobile Bay system by
effectively preserving, restoring and managing resources to maintain
adequate extent, diversity, distribution, connectivity, and natural
functions of all habitat types. |
|
Sub-objective I: Protect, enhance, restore and manage
valuable public lands and work with private property owners to establish
habitat protection goals on important privately held lands, including
the acquisition of 15 additional high priority sites through 2009 through
purchase or through other instruments such as easements. |
|
|
Sub-objective II: Maintain existing Submerged Aquatic
Vegetation (SAVs) at 2001 levels and increase acreage by 3% of known
areas where native SAVs occur by 2006. |
|
|
Sub-objective III:
Maintain and protect all types of coastal wetlands within the MBNEP
study area (including quality, function, and value)
and increase acreage by 5% of those types that have declined, by 2006. |
|
|
Sub-objective IV: Protect existing natural shoreline,
beach, and dune habitat and restore previously altered habitats, where
feasible, including the rehabilitation of altered shoreline by 1000
feet per year. |
|
|
Sub-objective V: Maintain and protect nesting habitat
for colonial and migratory birds and reduce declines in nesting habitat
due to human disturbance and alteration. |
|
|
Human Uses |
Human Uses Objective: Provide consistent, enforceable,
regional land and water use management that ensure smart growth for
sustainable development and decreases the negative impacts of growth-related
activities on human health and safety, public access, and quality of
life by developing and implementing plans consistent with the CCMP by
2006. |
|
Sub-objective I: Enhance quality of life by improved
planned and managed development. |
|
|
Sub-objective II: Reduce the negative effects of inadequately
planned and/or managed development on human health and safety. |
|
|
Sub-objective III:
Increase public access to water resources. |
|
|
Education and Public
Involvement |
Education and Public
Involvement Objective: Increase awareness of natural resources issues and promote
understanding and participation in conservation and stewardship opportunities. |
|
Sub-objective I: Increase public participation by
developing and implementing a comprehensive citizen-based monitoring
program. |
|
In critiquing this plan, we felt that the most effective method of focusing our critique would be construct a list of what we felt the broadest, most important principles of ecosystem management are, defining them, and giving the MBNEP CCMP a letter grade (on a standard scholastic A-F scale) to indicate how closely we felt it conformed to these standards. Following the grade is a brief explanation of how we determined the grade.
2.1 Sustainability:
Planning for the future is an essential aspect of any ecosystem management plan. Managing for present needs while preserving aspects necessary for continued ecosystem functioning is the immutable yardstick for success of any plan.
Grade: C
We felt that, while the Mobile Bay NEP does consider the future, timelines expressed in the plan are too short for real sustainability to be considered. Most aspects of the plan, while designed with an eye for sustainability are targeted to end in or before 2010. In the lifespan of an ecosystem, this simply isn’t enough time to make definitive judgments about whether actions taken are truly enough to be sustainable.
2.2 Ecological Integrity
Ecological integrity considers the protection of native diversity in order to ensure processes of the ecosystem remain functional over a wide range of spatial and temporal scales. In order to properly format a plan for preserving ecological integrity, it is also vital to consider the influences of other nearby ecosystems, at a variety of scales. This is clearly one of the major bases needed to judge an ecosystem management plan.
Grade: B+
This plan recognizes water-quality as the most far-reaching factor in the ecosystem. All important pollutants and aspects of water-quality are taken into account in a holistic fashion. The use of a permit process to control pollution sources is widely agreed to be the only effective means of control for such broad issues. Introduction of exotics is considered, a key factor affecting ecological integrity, as is retention of native biotic and abiotic components and processes. Unfortunately, due to political constraints, the planners are unable to consider the parts of the watershed outside of Alabama. This is clearly an important factor in developing a plan that considers the entire ecosystem.
2.3 Adaptive management
Adaptive management involves measuring the results of actions or inactions, and adjusting those actions or taking action, to produce the desired result. A prudent ecosystem management plan will take into account the necessity of altering plans depending on outcomes. This allows the plan to be as effective as possible over a wide breadth of spatial and, perhaps more importantly, temporal hierarchies.
Grade: B-
While the Mobile Bay NEP places a high priority on monitoring and data acquisition, it is sometimes unclear as to what they hope to gain from these data. Additionally, the temporal scale of the plan may be too short to really gather the appropriate data and evaluate them. Though this isn’t really the fault of the planners, it does pose a problem for the future of the plan. Monitoring and planning for potential growth of industry within the Estuary and its watershed is also not accounted for within the Plan. Working with established agencies and providing a clearinghouse for evaluation and distribution of data is an important function of the plan, and should help to improve adaptive management functions of involved agencies.
2.4 Human aspects
Human activities and values are important issues that must be considered when judging an ecosystem management plan. Does the plan take into account diverse user groups, such as recreational boaters, commercial farmers, and people who simply want to build homes in the managed area? Does the plan consider people’s needs, wants, and tolerance for restrictions or disruptions? Are people being educated to understand the reasons for the management decisions made, and the importance of the resources being managed?
Grade: B
This management plan has done a substantial amount of focus-group work, and given the non-coercive nature of the plan, consensus is extremely important. However, despite the use of public forums, an empirical study of people’s reactions to the management plan based on widely held values is lacking. A study of contingent valuation (concrete priorities), for example, is missing from the plan at this point.
2.5 Legislative aspects
This is a somewhat amorphous concept, but comprehensive understanding and utilization of bureaucratic agencies and regulations is essential to a successful ecosystem management plan. Laws such as the Endangered Species Act and issues relating to the compartmentalization of departmental duties are all considered under this heading.
Grade: A
The planners show a clear understanding of jurisdictional boundaries, and respect the authority of the various agencies involved. Interagency cooperation is a high priority throughout the plan, with the EPA, Alabama Department of Environmental Management, and other state and county authorities being involved in the management process. The Coast Guard, for example, is monitoring international shipping for pathogen introduction. This appropriate usage of various agencies is especially important because of the fact that the plan per se holds no authority to compel cooperation. Consideration of the ESA, Clean Water Act, and other regulations pertaining to the Estuary and its biotic and abiotic resources is also present.
3.0 Conclusions
The real strengths of the CCMP for the Mobile Bay Estuary lie in how it deals with organizing and providing structure to a wide variety of user groups and state and local agencies. From an organizational and social perspective, this is really a top notch plan.
Weaknesses for the most part seem less the fault of the planners than that of the system within they must work for the National Estuary Program. Lack of coercive authority means that specific actions must often be left up to individual agencies who may have other priorities than the planners. The plan ends in 2010 because it is difficult for the government to make the sort of never-ending commitment required for a long-term ecosystem management plan.
This plan earns a B average grade. Were it not for the short-sightedness and lack of clarity in the areas of Sustainability and Adaptive Management, it could easily be a B+ or better plan.