Trout Headwaters, Inc.’s Open Comments to The American National Standards Institute (ANSI) Regarding International Ecological Restoration Standards

THI has long worked to promote high professional standards in the ecological restoration industry – both domestically and internationally. Since the term ‘restoration’ is used for everything from stocking fish, to poisoning water, to armoring streambanks for flood protection, such standards are sorely needed.

Without solid ecological standards, and a scientific consensus on what constitutes successful ecological restoration, what can we really achieve?

In this case, the work of the ISO’s TC would also help support the United Nations Sustainable Development Goal 15, which serves to protect, restore and promote sustainable use of terrestrial ecosystems, sustainably manage forests, combat desertification, and halt and reverse land degradation and stop biodiversity loss. 

October 15, 2020

Mr. Steven Cornish
ANSI Senior Director of International Policy
New York City Operations

Dear Mr. Cornish,

Thank you for the opportunity to comment to the ISO technical committee on ISO/TS/P 293 Ecological Restoration Standards. 

For almost two decades, Trout Headwaters has been calling for standardized practice and evaluation standards, recognizing that progress in the science and practice of river and wetland restoration has been hampered by the lack of agreed-upon criteria for judging ecological success. Without well-accepted criteria that are ultimately supported by funding and acknowledged by regulatory agencies, there is little support for practitioners assessing or reporting restoration outcomes.

Improving methods and weighing the ecological benefits of various restoration approaches will require organized national-level reporting systems. Standards of practice can lead to more consistent results, help promote public safety, and allow designers and practitioners to better manage and monitor project outcomes.

I will keep my comments brief. In 2005 the National River Restoration Science Synthesis Working Group proposed five criteria for measuring success, published in the Journal of Applied Ecology (Palmer, et al. 2005). I believe these five criteria to still be relevant today, and I would encourage the committee to review these criteria in more detail.

One critically important point made by Palmer, et. al is, “Rather than attempt to recreate unachievable or even unknown historical conditions, we argue for a more pragmatic approach in which the restoration goal should be to move the river towards the least degraded and most ecologically dynamic state possible, given the regional context.”

Five criteria for ecological success, according to Palmer et. al, with which I concur:

1. A guiding image exists: a dynamic ecological endpoint is identified a priori and used to guide the restoration.

• Avoid one-size-fits-all stream classification systems based on common characteristics (i.e. Rosgen), which have led to many failures in North America (Kondolf, Smeltzer & Railsback 2001) because the specific processes and history of the river under study were not adequately understood. We believe the following warning should be strongly heeded:
  
  “Stream classification systems have been used as a basis for developing guiding images for restoration in North America and Europe. Classification (the ordering of objects into labelled groups based on common characteristics) has been broadly applied to river channels (Rosgen 1994; Poole, Frissell & Ralph 1997), with more than 40 geomorphically based classification schemes employed or proposed in various parts of the world, based on factors such as channel pattern, gradient, bed material size and sediment load (Kondolf et al. 2003). Experience to date suggests that classification systems work best as guides to restoration when they are developed for specific regions, like those used to develop the leitbild or guiding image for restoration of German rivers (Kondolf et al. 2003). Attempts to develop restoration designs based on application of a single classification system across many environments have led to many failures in North America (Kondolf, Smeltzer & Railsback 2001) because the specific processes and history of the river under study were not adequately understood.” (Palmer, et al. 2005)
  
• The first step in river restoration should be articulation of a guiding image that describes the dynamic, ecologically healthy river that could exist at a given site.
• A relatively undisturbed or already recovered reference sites can be used to help frame restoration goals
• An analytical or process‐based approach that employs empirical models can be used to guide the design of a project.
• Common sense may be adequate in many situations, where the guiding image is self‐evident and requires little or no expert analysis. All restoration projects need not be preceded by complex and expensive design. For example, areas with no riparian vegetation may simply need to be replanted and streams in farming communities may only need livestock to be fenced out to initiate ecological recovery.

2. Ecosystems are improved: the ecological conditions of the river are measurably enhanced

• Ecologically successful restoration will induce measurable changes in physicochemical and biological components of the target river or stream that move towards the agreed upon guiding image. Re‐establishment of an extirpated fish population, improved water clarity and quality, and establishment of a seasonally inundated meadow following dam removal are readily identified signs of ecological recovery.

3. Resilience is increased: the river ecosystem is more self‐sustaining than prior to the restoration

• Ecosystems are subject to changing conditions because of temporal variations in both natural factors and human activities.
• Ecologically successful river restoration creates hydrological, geomorphological and ecological conditions that allow the restored river to be a resilient self‐sustainable system, one that has the capacity for recovery from rapid change and stress
• To be ecologically successful, projects must involve restoration of natural river processes (e.g. channel movement, river–floodplain exchanges, organic matter retention, biotic dispersal).

4. No lasting harm is done: implementing the restoration does not inflict irreparable harm
   
5. Ecological assessment is completed: some level of both pre‐ and post‐project assessment is conducted and the information made available

• Ecological success in a restoration project cannot be declared in the absence of clear project objectives from the start and subsequent evaluation of their achievement (Dahm et al. 1995).
• Both positive and negative outcomes of projects must be shared regionally, nationally and internationally.
• Assessment is a critical component of all restoration projects but achieving stated goals is not a prerequisite to a valuable project. Indeed, well‐documented projects that fall short of initial objectives may contribute more to the future health of our waterways than projects that fulfil predictions.

Thank you again for the opportunity to comment.  We look forward to following the progress of the technical committee on this important endeavor.

Sincerely,

Michael C. Sprague, CEO
Trout Headwaters, Inc.
Livingston, MT
mike@troutheadwaters.com
www.troutheadwaters.com