DRAFT 2009_0923 PNAMP ISTM PROJECT PROPOSAL FOR HABITAT MONITORING TASKS Narrative Preamble: The 2008 Federal Columbia River Power System (FCRPS) Biological Opinion (BiOp) is a tenyear operations and configuration plan to mitigate for the adverse effects of the hydrosystem on the 13 listed fish under the Endangered Species Act (ESA). The BiOp provides mitigation actions that are required of the FCRPS action agencies to avoid jeopardy and adverse modification of the critical habitat of ESA listed Columbia River fish. Ongoing projects supported and new projects developed are designed to contribute to hydro, habitat, hatchery and predation management activities required under the 2008 FCRPS Biological Opinion. Additionally, the projects assist the Bonneville Power Administration (BPA) in meeting its protection, mitigation, and enhancement objectives and responsibilities by implementing the Columbia Basin Fish and Wildlife Program adopted pursuant of the Northwest Power Act. 1 Project Title: Development of a Coordinated Multi-Agency Habitat Monitoring Program in the Lower Columbia River ESU to Meet Regional Priorities for Salmon Recovery Table 1. Proposal Metadata: Project Number Title Development of a Coordinated Multi-Agency Habitat Status and Trends Monitoring Program in the Lower Columbia River ESU to Meet Regional Priorities for Salmon Recovery Proposer PNAMP ISTM Workgroup. Ecy, lcfrb, odfw,usfs The goal of this project is to develop a coordinated habitat monitoring program to assess the status and trend of tributary habitat conditions in the Lower Columbia River (LCR). This program will address priority monitoring questions to meet the needs of regional decision-makers and managers. The resulting program will inform and be repeatable in regions outside the LCR. Brief Description The specific objectives for this project include: 1) determine and prioritize monitoring questions and objectives for management agencies, including appropriate spatial and temporal scales; 1) determine adequacy of existing monitoring programs, potential efficiencies, and existing gaps; 3) identify feasible monitoring designs, sampling frames, protocols, and analytical tools; 4) develop a set of habitat monitoring recommendations for the LCR based on regional priorities established in Objective 1, cost-effectiveness, and a range of budgets.. Province(s) Columbia Estuary, Lower Columbia, Columbia Gorge Subbasin(s) Columbia Estuary, Lower & Lower Mid-Columbia Mainstem including Big Creek, Clackamas, Clatskanie, Cowlitz, Elochoman, Grays, Hood River, Kalama, Lewis, Little White Salmon, Lower Gorge tributaries, Scappoose, Sandy, Upper Gorge Tributaries, Washougal, Wind, Youngs Bay. Contact Name Bob Cusimano (WADOE) OTHERS? and Jen Bayer (USGS/PNAMP) Contact email [email protected], [email protected], ???? Projected Start Date January 1, 2010 2 A. Abstract In response to ESA listings for salmon and steelhead, federal and state agencies, local governments, private industry, and the tribes have invested substantial resources to restore and protect the ecological function of rivers and streams in the Pacific Northwest. One of the important salmon recovery needs is the ability to describe, with known certainty, the current status and long-term trends of the habitat conditions (physical, chemical, and biological conditions) of these aquatic resources. The goal of this project is to develop a coordinated habitat monitoring program for the Lower Columbia River ESU that meets these information needs and ultimately answers the question: “Are the primary habitat factors limiting the viability of the salmon and steelhead populations and ESU increasing or decreasing?” The objectives for this project include: 1) Determine and prioritize monitoring questions and objectives for management agencies, including appropriate spatial and temporal scales; 2) Determine adequacy of existing monitoring programs, potential efficiencies, and existing gaps; 3) Identify feasible monitoring designs, sampling frames, protocols, and analytical tools a. Identify a probability-based sampling design and site selection process (using a master sample from a linear based hydrographic system) that will allow for characterizing habitat status and trends throughout the LCR, to demonstrate the utility of the master sample approach for providing a consistent framework for regional habitat monitoring efforts; b. Evaluate need for common list of habitat indicators and metrics or potential habitat indexing protocol that can be used to compare and analyze metrics across programs for evaluating potential limiting factors; c. Integrate existing information and monitoring data, where possible, into the status assessment (may include data colleted outside of the master sample, as well as data collected from a master sample draw that would need different weighting); d. Supplement baseline status and trend assessments with remote sensing techniques to assess watershed and land-cover/land-use conditions within the ESU; 4) Develop a set of habitat monitoring recommendations for the LCR based on regional priorities established in Objective 1, cost-effectiveness, and a range of budgets; and 5) Recommend process for implementation, data management, reporting mechanisms, and adaptive management of monitoring. B. Problem Statement: technical and/or scientific background Human disturbance and natural alterations to watershed and stream regulating processes (characteristics of the riparian zone and channel) can decrease the amount of high-quality habitat in a watershed and disrupt the regeneration and maintenance of habitat for salmonid and aquatic species. Monitoring is needed to assess the status of listed species and their habitat, track progress toward achieving recovery goals, and provide information needed to refine recovery strategies and actions through the process of adaptive management. 3 Current monitoring for watershed and stream habitat conditions is poorly coordinated with limited ability to roll data up into comprehensive statistically valid assessments. A number of factors have contributed to the current disparate monitoring approaches adopted by monitoring entities. These factors include: 1) differing agency missions, programs, and monitoring needs; 2) differences (or perceived differences) in the questions and indicators that need to be addressed by the monitoring program; 3) different jurisdictions or spatial extents; 4) legacy of past monitoring programs (e.g. “we have always done things this way and need to maintain data continuity”); 5) differing levels of required scientific rigor; 6) needs for site specific monitoring or area based monitoring design and 7) differing levels of available funding. After considering the above factors, the PNAMP Integrated Monitoring Workgroup concluded that the geographic area encompassed by Lower Columbia Region (LCR) would be an appropriate place to demonstrate how a master sample could facilitate integration of watershed and stream data collection. This area is within the jurisdiction of two states (Oregon and Washington) and numerous federal, tribal, watershed, county, and municipal entities; is the focus of ongoing recovery efforts for four ESA listed anadromous salmonid species (coho, chum, Chinook, and steelhead), and bull trout; and has diverse land use and increasing human population pressures. Also this area uses multiple existing master samples draws, including the Washington’s Statewide habitat assessment design, the USFS AREMP, and ODFW master samples, and it provides opportunities to show how existing monitoring designs may be integrated. Using the LCR as a demonstration area will provide the opportunity to pilot the evaluation of monitoring methods and their bias and precision, and implement a comprehensive monitoring design across two states and multiple entities to assess instream and riparian habitat conditions on clearly defined regional priorities. The agencies involved in this proposed monitoring coordination project are responsible to collect data on watershed and stream attributes that are directly or indirectly related to salmon and trout environmental requirements. These data may be used to answer multiple questions at varying scales, including population/subbasin-level status and trend questions, as well as ESU-wide management and delisting questions. The Pacific Coastal Salmon Recovery Fund (PCSRF, 2008), Lower Columbia Salmon Recovery and Fish & Wildlife Subbasin Plan (LCFRB 2006), draft Lower Columbia River Conservation and Recovery Plan for Oregon Populations of Salmon and Steelhead (ODFW 2009), and FCRPS Biological Opinion identified the major limiting habitat factors that are potentially limiting salmon and trout survival and recovery in Washington and Oregon. Additional work by the Pacific Northwest Aquatic Monitoring Partnership (PNAMP), the Washington Forum on Monitoring, North West Executive Information Sharing (NWEIS) group and the Northwest Power and Conservation Council (NPCC) have identified high level indicators for habitat condition that are used in regional reports. However, current monitoring is not coordinated in a manner to support aggregating up data from various individual 4 sources to provide summary results across larger areas i.e. watersheds or basins. The proposed project will evaluate the need for consistent comparable indicators and metrics versus the use of a habitat classification index that would allow for comparison across disparate programs. One tool that may facilitate more compatible and consistent habitat data collection efforts is the development of a coordinated master sample design that can serve as the framework to support the further evaluation of indicators at various spatial and temporal scales. The utility of the master sample design concept is based on the basic assumption that it is not feasible to measure indicators of choice at all locations throughout a chosen stream network at the spatial scale that is of current interest (e.g., sub-basins, ESU/DPS scale, population scale, and state-wide). As a result, the demonstration will apply the concept of a sample survey by which representative locations are identified and sampled. Inferences with various degrees of certainty will then be able to be made at various scales based on data collected at the sample of sites. Where appropriate, the preferred technique is to select sites using a Generalized RandomizedTessellation Stratified (GRTS) design (Stevens and Olsen, 2004). This will apply the concept of a master sample consisting of a large number of locations identified using the GRTS design. A linear based master sample design for Oregon and Washington was created based on the 1:24,000 National Hydrography Data set (NHD), and will be used in this project to facilitate the use of a common master sample to monitoring stream and riparian conditions across the Northwest. While there is no doubt that the master sample concept is a tool that will be useful in designing many aspects of habitat monitoring, it may not be the most appropriate tool for the design of some aspect of habitat monitoring. This may be particularly true for conditions that are relatively rare along a stream network (such as impairment to fish passage), or indicators that can be economically measured by way of a census (such as remote sensing of upslope and riparian conditions). A major purpose of this monitoring coordination project is to report on recovery progress to federal and state administrators, Congress, the State Legislatures, and the public; therefore, it is essential that we choose parameters that can accurately portray progress. Remote sensing may provide a method to supplement baseline status and trends monitoring to help answer some broad-scale questions in an efficient manner. The combination of on-the-ground monitoring supplemented with remote sensing data may provide varying levels of information to address recovery progress at differing spatial and temporal scales. Goals and Objectives The goal of this project is to develop a coordinated habitat monitoring program that addresses key regional (priority) monitoring questions and develop study designs of sufficient quality and quantity to determine the status of LCR tributary habitat conditions in order to address the primary management question: “Are the primary habitat factors limiting the status of the salmon and steelhead populations and ESU increasing or decreasing?” 5 The proposal includes the following five objectives: 1. Determine and prioritize monitoring questions and objectives for management agencies, including appropriate spatial and temporal scales; The Lower Columbia Region provides a unique opportunity to evaluate status and trends of habitat conditions across a complex bi-state area with multiple listed salmonid species. One of the ultimate goals of this project is to assist management entities in making decisions and reporting on habitat status in relation to recovery of listed species. It is recognized that these decisions may need to occur at different spatial scales, as well as different temporal scales. For example, the status of habitat in a given county may be important to track the effects of local critical areas ordinances. In addition, the status of habitat loss or improvement in a subbasin may be important to answer questions about sharing recovery burden across impacts (habitat, harvest, etc). While ESA recovery plan priorities for the LCR will serve as the foundation for developing monitoring priorities, management agencies may have additional questions they need answered through habitat monitoring. These non-recovery-related monitoring goals may provide opportunities to extend existing long-term data sets, evaluate indicator streams, or provide information related to other management objectives. These monitoring goals are important to identify, as they may provide opportunities for efficiencies, more detailed data collection, or the use of differing monitoring techniques. While most management entities have a good sense of the questions they need answered, in order to develop a comprehensive, efficient monitoring program, it will be necessary to identify the relevant monitoring questions and objectives from all entities, as well as determine a method for their prioritization. This prioritization method may involve evaluating populations present within a geographic area, their recovery goal (Primary, Contributing, or Stabilizing), and other factors. The result of this objective will be a prioritized list of monitoring questions, including their appropriate spatial and temporal scales. This list should be able to be integrated with the concurrent effort to develop a comprehensive biological (fish) monitoring program. 6 Cascade Tilton River Upper Cowlitz River Lewis Lower Cowlitz River Grays River Pacific Cispus River Wahkiakum Elochoman Mill, River Abernathy & Germany Creeks Big Creek Youngs River Toutle River Cowlitz NF Lewis River Coweeman River Clatskanine River Big White Salmon River Kalama River Skamania Coast Scappoose Creek Wind River EF Lewis River Clark Salmon Creek Little White Slamon River Klickitat Upper Gorge Tribs Washougal River Lower Gorge Tribs Hood River Sandy River Clackamas River Clackamas River Gorge Figure 1. Lower Columbia Region 2. Determine adequacy of existing monitoring programs, potential efficiencies, and existing gaps; Many habitat monitoring programs exist in the LCR, and there have been numerous efforts to identify and document those programs by LCFRB, NOAA, ODFW, and others. This project will build on these existing inventories to identify potential efficiencies with ongoing monitoring programs. In addition, this project will identify gaps related to answering questions relevant to recovery objectives or other management objectives. These gaps and efficiencies may include overlap in monitoring programs, basins without adequate monitoring, and high priority basins to target with more frequent monitoring efforts. 7 3. Identify feasible monitoring designs, sampling frames, protocols, and analytical tools 1. Identify a probability-based sampling design and site selection process (using a master sample from a linear based hydrographic system) that will allow for characterizing habitat status and trends throughout the LCR, to demonstrate the utility of the master sample approach for providing a consistent framework for regional habitat monitoring efforts Determining the status and habitat trends over time over a large geographic area like the LCR can be accomplished with a census or random sampling. A census by definition requires every unit of a population to be measured. Since this approach is often impractical, random samples of the population are taken to make statistical inferences about a population with known confidence. This project is based on a probability-based sampling design and site selection process and is consistent with and complimentary to the recent PNAMP project that is being implemented in the LCR to develop and implement a master sampling design that can be used to integrate fish and habitat monitoring. Our population of interest is the linear stream network and results from the project will be expressed in terms of length (kilometers, miles) or percent population length. Within this population, data gathered needs to be able to answer questions at a variety of spatial scales for a variety of management agencies. GIS data for existing boundaries may be used to guide scope and site selection (sample draws). These data sets include: Salmon Recovery Region (SRR) Willamette/Lower Columbia TRT Population Designations (http://www.nwfsc.noaa.gov/trt/mapsanddata.cfm) WA Water Resource Inventory Area Strata/Ecoregion Physiographic zones County USGS Hydrologic Unit Ownership (federal, state, private) Stream habitat restoration priority tiers (LCFRB) Distribution for each listed species Stream layers Because existing monitoring programs collect data focused on a variety of spatial scales, the proposed project will document what attributes were used in the site selection process for the existing designs. For example how are the GIS data for Water Resource Inventory Areas (WRIAs), federal or state lands, ESA populations, Hydrologic Unit Codes (HUCs), ecoregions, bio-geographical regions, or priority stream reaches used to determine scope and site selection. This information will be critical in determining monitoring gaps that need to be filled, as well as how existing monitoring data can be integrated into the overall design (Objective 3c). For example, the LCFRB’s Research, Monitoring, and Evaluation Program recommends the following sampling targets to represent conditions at the subbasin level: samples in each of 8 18 subbasins, 3 physiographic zones, 4 stream orders and 3 replicates in each strata (648 samples total). This sampling scheme could be repeated on a 12 year rotating panel to incorporate status and trend monitoring goals. It may also be appropriate to incorporate monitoring at sensitive indicator sites on a more frequent (3-year) rotation to detect trends over a shorter time scale. The resulting sample design and process for its development should be repeatable in regions outside the LCR. b. Evaluate need for common list of habitat indicators and metrics or potential habitat indexing protocol that can be used to compare metrics across programs for evaluating potential limiting factors; Due to the number of disparate ongoing monitoring efforts across the region, there exists a need to make data comparable. One option to this end is to develop a common list of habitat indicators and metrics that implementers agree to use in data collection. These indicators and metrics can then be used to evaluate potential salmon and steelhead limiting factors at multiple scales. Indicators may be based on PNAMP HLI recommendations (PNAMP 2009), the ongoing work from the PNAMP monitoring glossary project, LCFRB and ODFW Recovery Plan indicators and metrics, and the FCRPS RM&E workgroup. This option would ultimately result in a list of habitat monitoring metrics and indicators using controlled vocabulary to facilitate , or ensure interoperability and data exchange of information. Currently each agency may use various synonyms/aliases for the same term or they may use variations of summary metrics based on core metrics collected in the field. Another option would be to develop an index system that would allow data collected using a variety of methods to be compared as indicators of watershed condition or health. For example, a rating for a subbasin could be expressed as a numeric score from 1-100 by aggregating individual metric scores into an index. This would allow data collected for varying purposes to be compared at a broader scale to answer questions about habitat status. This project will evaluate the benefits and drawbacks of each option, incorporating the appropriate management agencies, and determine the preferred course of action. c. Integrate existing information and monitoring data, where possible, into the status assessment (may include data colleted outside of the master sample, as well as data collected from a master sample draw that would need different weighting); In collaboration with ongoing PNAMP Master Sample design project (Oregon State University is responsible for the development of the master sample and web-based tracking tool), this project will identify how existing monitoring programs may be integrated into the new regional master sample or into a specific new design. This will identify how existing sites may be associated to the new master sample draw points and how they sites may be weighted. For example if the AREMP program has 5 sites in federal lands in a watershed and WA ECY has 2 new site on state lands, and the LCFRB has the desire for 9 total sites distributed across 3 biogeographical regions, how would AREMP the sites be weighted to support a spatially balanced sample and evaluation. 9 This project will also identify the steps needed to incorporate monitoring from existing programs that are not based on probability designs and what the limitations are for inclusion. For example how could an existing water quality monitoring station for a county be incorporated into a design and weighted. Note: this will not focus on the compatibility of data or the confidence intervals around data associated with various field monitoring data collection methods and protocols. This project will identify the constraints for site incorporation into a master sample. This should identify what the limitations are and what factors are considered for weighting a value of an existing monitoring site. d. Supplement baseline status and trend assessments with remote sensing techniques to assess watershed and land-cover/land-use conditions within the ESU; Remote sensing is currently used to assess land-cover and land-use conditions within the Lower Columbia ESU. This ongoing monitoring effort could be tied into the overall monitoring strategy. While this tool may not be directly tied to the master sample, the information gathered from remote sensing could be used to fill gaps or detect broad-scale changes in an efficient manner. Using geographic information system (GIS) and remotely sensed data to describe habitat conditions in the Lower Columbia River Salmon Recovery Region has potential to efficiently provide data describing the conditions of upland and riparian habitat, and perhaps of some important features of large streams or rivers. There are several advantages to sampling using GIS and remote sensing, including the ability to reduce temporal variability by collecting all data in a short time, high certainty of site access, and permanent records of data that allows for continued development of methods and reanalysis. Furthermore, the cost of procuring GIS and remotely sensed data has been decreasing while the cost of field sampling has been increasing rapidly. Remote Sensing Data Three types of remotely sensed data might prove useful for habitat monitoring and evaluation: Satellite-derived data (e.g., LANDSAT TM) can provide a coarse census of land use and land cover throughout the Recovery Region. Such data are frequently available, cost little to procure, have a long period of record to allow trend detection, and standard methods of analysis are developed. The Interagency Mapping and Assessment Program (IMAP) recently finished an assessment of wall-to-wall vegetation cover type, seral stage, and changes over the past 15 years for the states of Washington and Oregon. This partnership included the participation of the Washington Department of Natural Resources. The assessment is expected to be repeated on five-year intervals. The Status of Vegetation maps can be found at these two websites: 10 o http://www.fsl.orst.edu/lemma/main.php?project=nwfp&id=studyAreas o http://www.fsl.orst.edu/lemma/main.php?project=imap&id=studyAreas The Aquatic and Riparian Effectiveness Monitoring Program staff is using IMAP data as part of their efforts to characterize watershed condition: o Hydrologic recovery (based on stand maturity) is determined by vegetation cover found at rain-on-snow elevations; o Hydrologic connectivity is partly evaluated by the proportion of the watershed that has been converted to urban or agricultural uses; o Riparian stand maturity is based on percent riparian with large conifers and hardwoods; and o Landslide risk is partly determined by the amount of forested and non-forested areas. Low-level high-resolution aerial photography can be used to supplement satellite-derived data. Photographic sampling can provide accurate, high resolution descriptions of land cover and land use for parts of the landscape that importantly effect salmon (e.g., riparian zones). Attributes such as the presence of large wood can be tallied in large streams and rivers with little canopy cover. However, some further work will likely be required to provide standard methods of image processing and data analysis. Alternatively, where and when available aerial photographs can be procured from ongoing programs such as the National Agricultural Imagery Program (NAIP) from the U.S. Department of Agriculture (USDA). The USDA is amenable to providing supplemental remotely sensed data (e.g., different sensors and additional sampling periods) and alternative sampling methods (e.g., different areas and different resolutions). Finally, light detecting and ranging (LiDAR) data can provide a useful, high resolution description of bank conditions (e.g., presence of dikes) and stream morphology (e.g., floodplain width, channel gradient). Overlaying LiDAR and aerial photography data can provide an informative description of the status of upland and riparian conditions that effect instream habitat conditions. Because LiDAR data are relatively expensive to procure and process, their procurement might often be limited to priority areas. Some LiDAR data are available from the Puget Sound LiDAR Consortium. 11 Remotely sensed data usually do not provide the high resolution descriptions of stream habitat that is often desired for monitoring. However, it can be a cost effective alternative to collecting some field data and might prove sufficient to address many questions. When a census is not feasible, sampling is often used. However, appropriate sampling schemes for collecting remotely sensed data to describe stream systems are little developed. Point sampling using remote sensing is usually inefficient. Spatial units that describe the habitat for priority populations can be prioritized for a census via aerial photography and LiDAR. Further, stream types or specific locations (e.g., non-wadeable streams) can be identified and prioritized for sampling. Methods for appropriately integrating remotely sensed data that describe conditions across large spatial extents with field data collected at randomly selected locations for status and trend monitoring remain to be fully developed. Geographic Information System (GIS) GIS data are useful for calculating environmental attributes that describe habitat at different spatial extents. It can also be used as a surrogate for upslope and riparian processes. For example, a GIS can be used to measure the spatial location of roads in relation to stream crossings, hill slopes and riparian areas, which are used as a surrogate for sediment delivery to streams. Various GIS stream layers are available at different scales and other types of GIS data (e.g., soil types) are being developed. Some advantages of using GIS are that data are readily 12 accessible to different users, data continue to be improved, spatial coverage is expanding, and analytical methods are improving. However, coordination of data is often challenging; more than one layer may exist for an attribute. For example, in Washington data users are still developing a shared, standard GIS stream layer. Roads can affect ground water interception, shade, floodplain loss, channel modification (stream straightening), connectivity (passage for fish, sediment, wood), channel complexity, and flow interception. Because it is difficult to directly measure these impacts, road attributes are often used as surrogates to describe watershed processes. The Aquatic and Riparian Effectiveness Monitoring Program staff is using the following road GIS data as part of their efforts to characterize watershed condition.; Number of road-stream crossings; Miles of road (paved and unpaved) in riparian areas; Proximity of roads to streams; Steepness of slope where roads occur; and Influence of road density on landslide risk. The following are preliminary results for status and trend of a road-stream crossing attribute for the Oregon Coast aquatic province. Road Crossing Scores 1994 2009 I-5 Trend I-5 I-5 13 Trend Data Status Data +0.61 to 1.0 + 0.2 to 0.6 -0.19 to +0.2 -0.59 to -0.2 -1.0 to -0.6 +25% +15 - 24% +5 - 14% -4 - +4% -5 - 14% -15 - 24% -25% The Pacific Northwest Regional Geographic Information Council (PNW-RGIC) is composed of federal, state, local, and tribal members from Oregon, Washington, and Idaho who are dedicated to assisting regional stakeholders by coordinating, promoting, and enabling the development, distribution, and maintenance of regionally and nationally significant geospatial data sets. See http://pnw-rgic.wr.usgs.gov/about.htm for more information about PNW-RGIC. 4. Develop a set of habitat monitoring recommendations for the LCR based on regional priorities established in Objective 1, cost-effectiveness, and a range of budgets. The primary result of this effort is a monitoring program that allows entities to determine the status and trend of habitat conditions in the LCR. This program should incorporate the appropriate spatial and temporal scales necessary to answer the priority monitoring questions identified in Objective 1. These questions will include both recovery-based goals and other management goals and constraints. The resulting program will include a detailed plan for implementation at varying funding levels, recognizing the need to take advantage of existing programs while ensuring adequate sampling coverage. The resulting program will be integrated with ongoing methods to monitor fish population status and trends, as well as ongoing efforts to design an estuary monitoring program. 5. Recommend process for implementation, data management, reporting mechanisms, and adaptive management of monitoring. Based on the set of prioritized recommendation for habitat monitoring developed in objective 4, recommendations will be made on the most appropriate ways to implement the monitoring (i.e. lead entities, cost estimates, etc.), data management needs, and reporting mechanisms. This objective recognizes the need for flexibility in the monitoring design. As data are analyzed to answer the various questions identified in Objective 1, the scale and frequency of sampling may need to be adjusted. Over time, additional management questions may arise that would cause the need to adjust the sampling scheme. This project will identify points where the efficacy of the sampling design is evaluated. This evaluation should involve the relevant management agencies and look for potential refinements and efficiencies, as well as potential deficiencies in the sampling program. This adaptive management program might 14 also look for opportunities to incorporate additional monitoring goals such as project effectiveness monitoring and critical uncertainties research, if appropriate. 15
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