October 1, 2002

Independent Scientific Review on the
Everglades and South Florida Ecosystem Programs

Chief of Engineers'
Environmental Advisory Board (EAB)

Issue Paper No. 1

Pertinent Legislation:

Section 601(j) of the Water Resources Development Act of 2000 (Public
Law106-541) (http://www.evergladesplan.org/the_plan/2lev_legislation.shtml)
includes a provision requiring independent scientific review of the
Comprehensive Everglades Restoration Plan's (CERP) progress toward achieving
the natural system restoration goals.  Specifically subsection (j) this
legislation reads as follows:

   (j).  INDEPENDENT SCIENTIFIC REVIEW. -

   (1) IN GENERAL. - The Secretary [of the Army], the Secretary of the
       Interior, and the Governor, in consultation with the South Florida
       Ecosystem Restoration task Force, shall establish an independent
       scientific review panel convened by a body, such as the
       National Academy of Sciences, to review the Plan's progress toward
       achieving the natural system restoration goals on the Plan.

   (2) REPORT. -  The panel described in paragraph (1) shall produce a
       biennial report to Congress, the Secretary [of the Army],
       the Secretary of the Interior, and the Governor that includes an
       assessment of ecological indicators and other measures of progress
       in restoring the ecology of the natural system, based on the Plan.

Background:

Given the complexities associated with environmental restoration, the keys
to success are sound scientific practices.  In the context of CERP
implementation and its various science based decision-making forums, how and
when to employ peer review and who is best suited to perform it is often
debated.  The works in question are typically developed by CERP aligned
Federal, state and local agencies, native American tribes, stakeholders, and
special interest groups and the reviewed items include primarily technical
reports, including hydrological and ecological / biological performance
and/or the numerical models used to compose them.

Since the inception of the CERP, a number of candidate entities have been
chartered or have assumed this science oversight mission.  However, in the
pursuit of pure, objective and independent scientific review, these entities
have produced reports in the absence of a guiding and universally agreed
upon scientific and networked review process.  Consequently, the utility and
acceptance of these reviews are often questioned and frequently challenged.
 The debate should not focus on who is best suited to perform this
independent scientific review, but how it should be performed.  A widely
accepted process or methodology to conduct independent scientific review is
needed.  This is especially applicable to the review of the technical
complexities of the CERP.  Many organizations (government and
non-government) seek to submit scientific findings or "truths" into the CERP
decision-making process or bar these admissions.  Those motivated to either
submit or reject a finding usually seek a forum for those submittals to be
tested (peer reviewed).

Key Concepts:

A process for CERP that is suited for conducting independent scientific
reviews is both required and much needed and the EAB recommendations are of
the utmost importance as the South Florida Ecosystem Restoration Task Force
(http://www.sfrestore.org), of which the Department of the Army is a key
member, has plans to address this topic in the months ahead.

In the Corps of Engineers view this process should have these
characteristics:

 · It should not be vested in only one place or in one organization.

 · The process methodology should be designed so it may be administered
   independent of the originator of the work under review.

 · "Independent" and the context of this independence must be defined.
   Is independence based on the characteristics of individuals, an agency
   or an association with an organization?  Are there other criteria and
   principles in play that should be described?

 · The process should rely on the strategic selection of reviewers and
   not be self-selecting.  It should not be a process that requires agency
   representation as a driving factor in the selection of reviewers.

 · The process must be designed to let peer reviewers succeed
   (proper amount of time, funding, proper framing of questions and issues
   to be addressed, and appropriate background information).

 · The subject matter suitable for an independent review should be
   identified, such as: models, precedent setting scientific reports,
   emerging technologies, innovative approaches, policy implications
   (these may be scientific as well as social and economic issues), and
   issues that address uncertainty.

 · The process should have provisions for various levels or rigors of
   review.  In other words, the effort applied should be suitable or
   matched to the issue in question.

 · The process should have reiterative feedback loops that permit
   communication between the reviewers and the originators of the items
   under review.  Disagreement may remain between those performing the
   review and authors of the reviewed items.  However, the process must be
   accepted as a fair forum to reveal legitimate differences in
   professional opinion.

There will certainly be other characteristics put forward for consideration
when designing this effort.  The review forum may include ad hoc panels, or
standing pool(s) of experts.  These pools may include experts independent of
CERP, its agencies and affected parties as well individuals that are
affiliated with these CERP related groups.

What will ultimately be submitted to this process will be determined by the
technical and policy needs or concerns raised by organizations like the
South Florida Water Management District's - Water Resources Advisory
Commission (WRAC) (http://www.sfwmd.gov/gover/wrac/main.html), the National
Academy of Sciences - Committee on Restoration of the Greater Everglades
Ecosystem (CROGEE) (http://www.sfrestore.org/crogee), the South Florida
Ecosystem Restoration Task Force's - Science Coordination Team,
(http://www.sfrestore.org/sct/index.html), the Restoration Coordination and
Verification (RECOVER) teams
(http://www.evergladesplan.org/pm/recover/recover.shtml) and other
identified bodies working in CERP related science development and
utilization arenas.

CROGEE is a scientific review body that should clearly be a user of this
process.  However, it is not currently the best place to exclusively "house"
it.  Its past actions suggest that they are not positioned to meet the
timeframes required for most applications or review needs.  Furthermore,
CROGEE is not designed to accommodate the focus and specific scientific
rigors required to accomplish the entire CERP peer review mission.

The Scientific Coordination Team is also a likely user of the process,
however, it may not be the appropriate forum for managing it due to its
members' organizational affiliations.  These affiliations serve to erode a
perception of independence.

An example of a scientific review process worthy of examining is described
in the South Florida Water Management District's - 2002 Everglades
Consolidated Report (http://www.sfwmd.gov/org/ema/everglades/index.html).
This perhaps is a good start for developing a review mechanism.  In the
Corps view this report has these qualities:  A review process that is
transparent (open for public viewing); it is one that is designed to permit
the free exchange of information between peer reviewers and those that may
have developed the item under review; the management of the process and
development of the final review product can be directed by an independent
body; and this process has been in use and tested in the real world for four
years.  It appears to be working.  At a minimum, lessons learned from this
effort would be valuable when crafting a CERP Independent Scientific Review
process.

PREPARED BY:  Gary Hardesty, Program Manager
              Everglades Restoration Program
              (202) 761-5854
              Gary.M.Hardesty@USACE.ARMY.MIL
              Headquarters, U.S. Army Corps of Engineers (CECW-B)
              October 1, 2002

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