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UPDATE: We are in the middle of building a complete repository of improvement claims. The Puget Sound Partnership has been mining critiques of the Puget Sound Recovery system from over the last 10 years (we found 30 publications!) Most of the claims from these reports are limited to a sentence or two of text, and are vague and simplistic--not sufficient to guide improvement. While some of these claims are unique to the Puget Sound, we believe the themes and issues are common to all ecosystem management settings.
We have peeled out a set of claims that relate to our Planning and Funding System. are using the results of this archival work to facilitate a conversation
Sources for Claims
Here is a collection of reports that identify gaps, barriers, or problems that has been informing our work:
- File:SRFB 2019 large project barriers.pdf - a presentation of the results of a survey of projects sponsors about what is preventing them from working on large projects.
- File:Cereghino 2019 DRAFT project description problem focus group.pdf - output of a day-long workshop to define strategies for reducing redundancy in project applications over a project lifecycle.
- File:Cereghino et al 2018 evaluating acquisition systems.pdf - describes risks in our acquisition systems.
- File:MC2 2018 lead entity lean study.pdf - a intensive examination of funding processes in the RCO state salmon system.
- File:Ryan-Penula et al 2017 LIO plan summary analysis.pdf - summarized "gaps and barriers" identified by LIOs
- Canty 2015 describes feedback to EPA about how to develop an effective program that achieves reach scale protection and restoration in the riparian zone.
- File:Cereghino 2015 grant administrative streamlining.docx describes an analysis of the steps necessary to develop a shared information architecture that could accelerate collaboration.
- File:Cereghino 2015 accelerating estuary restoration.pdf describes the barriers faced by 65 regional project managers working on large estuary restoration, including a critique of some dynamics in the grant system.
- Sahandy & Daily 2014 uses interviews to explore barriers to efficient local watershed coordination that could be solved by grant programs.
- Blackmore 2009 summarizes interviews that explore barriers to large project implementation in Puget Sound salmon recovery.
The Claim List
This is a list of claims (as of 9/9/19) about how we could improve ecosystem management. These claims may not all be accurate or precise. Each claim came from a member of a local ecosystem recovery team, either through a personal communication or an on-line form. Claims have been rewritten by the Continuous Improvement Team, in an attempt to offer neutral and consistent language while retaining clarifying detail. No claim has been discarded.
Our claims are organized into three systems.
- Planning and Funding System - by which we allocate resources to pay people to do protection and restoration. Most of this is through appropriation and capital programs.
- Regulation and Mitigation System - where we exercise state and federal authority to constrain the actions of citizens. These authorities create mitigation markets.
- Monitoring and Learning System - where we make observations of the social or ecological systems to learn what we should do next or evaluate the effects of our actions.
Of course, these three systems interact. Some claims are broad while others are specific. Some could be addressed by process improvement, while others require innovation. Some may point to deeply seated social conflicts, only addressed through social-political negotiation.
Plan and Fund System Claims
|Meeting Travel Vortex
|Remote and web-cast meetings need to be standard and efficient to reduce wasted effort in coordination.
|State and federal agencies lack the ability to analyze, remember and act on complaints about interagency function that come from the ecosystem management field.
|No Local Notification
|State-federal programs have no efficient mechanism for providing information about program activities to local teams, reducing beneficial impacts.
|Commerce Not at ECB
|Commerce implementation of Growth Management Act is central to ecosystem recovery, and absent from the Ecosystem Coordination Board deliberations.
|Action Agenda System Performance
|The processes that lead primarily to the distribution NEP funds as implemented under the Action Agenda framework has resulted in a large redundancy of effort.
|Grant Reporting Redundancy
|Each grant and planning system assigns unique reporting and data management tasks diverting limited local capacity from ecosystem management, and undermining collective reporting.
|No Grant Budget Coordination
|Project managers waste resources managing a unique budget for each grant to meet application requirements.
|Large Project Budget Standards
|No Master Application
|Each funding program requires similar but slightly different applications to describe projects, causing local teams to expend labor re-describing a project and potentially stimulating waste in administration and reporting.
|Grant Matching Cost
|Administration of grant match consumes critical resources limiting the rate of ecosystem recovery with unclear benefits.
|No Single Funding List
|There is no centralized location for funders to view and anticipate funding opportunities among federal, state and private programs.
|Washington Water and Salmon Fund Finder
|No Performance Measure Standards
|The use of different performance measures among programs undermines regional performance reporting.
|No Coordinated Geographic Acquisition Priorities
|Different programs offer different acquisition, lease, and incentive tools and have different priorities, preventing field teams from operating with a full toolkit in any one geography.
|Funding Schedule Impacts
|Grant program individually set the timing of RFPs and contract periods in a way that creates a range of unintended consequences.
|Poor Stewardship of Acquisitions
|Once acquired, conservation lands have weak mechanisms for long-term stewardship, unsupported by state-federal resources.
|Weak Flood Hazard/Ecosystem Integration
|Floodplain management occurs under multiple authorities, operating in the same environment, with potentially conflicting goals and methods.
|Difficult CREP Extension
|CREP re-enrollment at the end of the lease is constrained, which creates a risk of losing protections.
|Habitat Work Schedule ROI
|The Habitat Work Schedule is a redundant and expensive tool, the use of which is driven by complex issues, with a potentially low return on investment.
|County Contracting Increases Costs
|Local governments using pre-approved road contracting rosters for restoration work may in more expensive project costs.
Regulation and Mitigation System Claims
|Culvert Replacement Regulation
|Regulatory review of culvert modification is unpredictable and expensive, which shouldn't be the case a project type where there is agreement over urgency.
|Snohomish Culvert Replacement Regulatory Coordination
|Regulatory Spatial Standards
|Different definition and mapping of critical areas across all jurisdictions creates uncertainty and cost for project development and regulatory implementation.
|Soft Armoring Regulation
|Innovation in shoreline armoring is disincentive through increased costs and uncertainty during regulatory review.
|The large investment necessary to create an in-lieu fee or banking system undermines the creation of real costs for ecosystem degradation.
|Ecosystem Service Payment Inventory
|We have no mechanism for efficiently sharing lessons from pilot efforts in ecosystem markets to improve the next effort.
|Riparian Zone Management Flexibility
|Reforestation reduces landowner control of their riparian zone, creating an unintended disincentive to participate in recovery.
|Federal Levee Modification (s.408)
|USACE lacks the capacity to respond early in the design process to modify federal flood infrastructure, increasing risk in pursuing expensive feasibility work without understanding federal constraints.
|Agricultural Drainage Maintenance
|Agricultural drainage system regulation dramatically increases costs of operation, and when combined with lack of enforcement discourages participation in recovery.
|French Slough Drainage Management (Aborted)
|Regulatory agencies are not organized or equipped to attract land owners to become partners in recovery, resulting in lost opportunity and capacity.
|Regulation would benefit from a watershed-based authority with broad representation that can rapidly and efficiently approve small and mid-scale projects, to enable recovery.
|Shoreline Armoring Jurisdiction
|USACE has declined to claim jurisdiction over shoreline construction above MHHW, allowing shoreline modification to avoid federal review.
|USACE Permits Delays
|Currently it takes too long to obtain US Army Corps of Engineer Regulatory Permits or amendments to existing permits.
|Wetland Change During Restoration
|Floodplain wetland change during restoration, even if beneficial, increases regulatory complexity, resulting in unpredictable delays or costs.
|Buffering in Agricultural Wetlands
|Wide buffer requirements reduce the number of landowners becoming involved in stewardship of agricultural wetlands.
|Barriers to Infill
|Local jurisdictions have difficulty increasing density in order to meet the intent of the growth management act.
|Regulation does not prevent ongoing ecosystem degradation.
|Sediment Release During Restoration
|Applying construction turbidity control requirements to in-stream restoration is unrealistic and drives up restoration project cost.
|Reduced Fish Enhancement Exemption
|Fish Enhancement exemption use has reduced over time increasing project costs and time.
|Restoration Triggers Re-Mapping Study
|Each restoration project in a floodplain may require a re-mapping study under FEMA requirements, greatly increasing cost or delaying restoration.
|Permit Data Management
|The simplification of water quality permit data undermines its potential use to adjust program activities as this data is aggregated.
|Reduced Use of NW27
|Fewer of our current restoration actions are being reviewed under the USACE Nationwide Permit #27.