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Appendix A - Common Questions and Their Answers
Q.
How will implementing biological criteria benefit State water quality
programs?
A. State water quality programs will benefit from biological criteria
because they:
a)directly
assess impairments in ambient biota from adverse impacts on the environment;
b)are defensible and quantifiable;
c)document improvements in water quality resulting from agency action;
d)reduce the likelihood of false positives (i.e., a conclusion that attainment
is achieved when it is not);
e)provide information on the integrity of biological systems that is compelling
to the public.
Q.
How will biological criteria be used in a permit program?
A. When permits are renewed, records from chemical analyses and
biological assessments are used to determine if the permit has effectively
prevented degradation and led to improvement. The purpose for this evaluation
is to determine whether applicable water quality standards were achieved
under the expiring permit and to decide if changes are needed. Biological
surveys and criteria are particularly effective for determining the quality
of waters subject to permitted discharges. Since biosurveys provide ongoing
integrative evaluations of the biological integrity of resident biota,
permit writers can make informed decisions on whether to maintain or restrict
permit lim its.
Q.
What expertise and staff will be needed to implement a biological criteria
program?
A. Staff with sound knowledge of State aquatic biology and scientific
protocol are needed to coordinate a biological criteria program. Actual
field monitoring could be accomplished by summer-hire biologists led by
permanent staff aquatic biologists. Most States employ aquatic biologists
for monitor ing trends or issuing site-specific permits.
Q.
Which management personnel should be involved in a biologically-based
approach?
A. Management personnel from each area within the standards and
monitoring programs should be involved in this approach, including permit
engineers, resource managers, and field personnel.
Q.
How much will this approach cost?
A. The cost of developing biological criteria is a State-specific
question depending upon many variables. However, States that have implemented
a biological criteria program have found it to be cost effective (e.g.,
Ohio). Biological criteria provide an integrative assessment over time.
Biota reflect multiple impacts. Testing for impairment of resident aquatic
communities can actually require less monitoring than would be required
to detect many impacts using more traditional methods (e.g., chemical
testing for episodic events).
Q.
What are some concerns of dischargers?
A. Dischargers are concerned that biological criteria will identify
impairments that may be erroneously attributed to a discharger who is
not responsible. This is a legitimate concern that the discharger and
State must address with careful evaluations and diagnosis of cause of
impairment. However, it is particularly important to ensure that waters
used for the reference condition are not already impaired as may occur
when conducting site-specific upstream-downstream evaluations. Although
a discharger may be contributing to surface water degradation, it may
be hard to detect using biosurvey methods if the waterbody is also impaired
from other sources. This can be evaluated by testing the possible toxicity
of effluent-free reference waters on sensitive organisms. Dischargers
are also concerned that current permit limits may b ecome more stringent
if it is determined that meeting chemical and whole-effluent permit limits
are not sufficient to protect aquatic life from discharger activities.
Alternative forms of regulation may be needed; these are not necessa rily
financially burdensome but could involve additional expense. Burdensome
monitoring requirements are additional concerns. With new rapid bioassessment
protocols available for streams, an d under development for other surface
waters, monitori ng resident biota is becoming more straightforwar d.
Since resident biota provide an integrative measure of environmental impacts
over time, the need for continual biom onitoring is actually lower than
chemical analyses and generally less expensive. Guidance is being developed
to establish acceptable research protocols, quality assurance/quality
control programs and training opportunities to ensure that adequate guidance
is available.
Q.
What are the concerns of environmentalists?
A. Environmentalists are concerned that biological criteria could
be used to alter restrictions on dischargers if biosurvey data indicate
attainment of a designated use even though chemical criteria and/or whole-effluent
toxicity evaluations predict impairment. Evidence suggests that this occurs
infrequently (e.g., in Ohio, 6 percent of 431 sites evaluated using chemical-specific
criteria and biosurveys resulted in this disagreement). In those cases
where evidence suggests more than on e conclusion, independent application
applies. If bi ological criteria suggest impairment but chemical- specific
and/or whole-effluent toxicity implies attainment of the use, the ca use
for impairment of the biota is to be evaluated and, where appropriate,
regulated. If whole effluent and/or chemical-specific criteria imply impairment
but no impairment is found in resident biota, the whole-effluent and/or
chemical-specific criteria p rovide the basis for regulation.
Q.
Do biological criteria have to be codified in State regulations?
A. State water quality standards require three components: (1)
designated uses , (2) protective criteria, and (3) an antidegradation
cla use. For criteria to be enforceable they must be codif ied in regulations.
Codification could involve genera l narrative statements of biological
criteria, numeric criteria, and/or criteria accompanied by specific testing
procedures. Codifying general narratives provides the most flexibility-specific
methods for data collection the least flexibility-for incorporating new
data and improving data gathering methods as the biological criteria program
develops. States should carefully consider how to codify these criteria.
Q.
How will biocriteria fit into the agency's method of implementing standards?
A. Resident biota integrate multiple impacts over time and can
detect impairment from known and unknown causes. Biocriteria can be used
to verify improvement in water quality in response to regulatory efforts
and detect continuing degradation of waters. They provide a framework
for developing improved best management practices for nonpoint source
impacts. Numeric criteria can provide effective monitoring criteria for
inclusion in permits.
Q.
Who determines the values for biological criteria and decides whether
a waterbody meets the criteria?
A. The process of developing biological criteria, including refined
use classes, narrative criteria, and numeric criteria, must include agency
managers, staff biologists, and the public th rough public hearings and
comment. Once criteria are established, determining attainment\nonattainment
of a use req uires biological and statistical evaluation based on established
protocols. Changes in the criteria would require the s ame steps as the
initial criteria: technical modifications by biologists, goal clarification
by agency managers, and public hearings. The key to criteria development
and revision is a clear statement of measurable objectives.
Q.
What additional information is available on developing and using biological
criteria?
A. This program guidance document will be supplemented by the document
Biological Criteria Development by States that includes case histories
of State implementation of biological criteria as narratives, numerics,
and some data procedures. The purpose for the document is to expand on
material presented in Part I. The document will be available in October
1 990. A general Biological Criteria Technical Reference Guide wil l also
be available for distribution during FY 1991. Thi s document outlines
basic approaches for developing biolog ical criter ia in all surface waters
(streams, rivers, lakes, wetlands, estuaries). The primary focus of the
document is to provide a reference guide to scientific literature that
describes approaches and methods used to determine biological integrity
of specific sur face water types.
Over the next triennium more detailed guidance will be produced that focuses on each surface water type (e.g., technical guidance for streams will be produced during FY 91). Comparisons of different biosurvey approaches will be included for accuracy, efficacy, and cost effectiveness.