Assistant Administrator, Office of Water

Mr. Benjamin Grumbles

Assistant Administrator, Office of Water

U.S. Environmental Protection Agency

ArielRiosBuilding

Office of Water

1200 Pennsylvania Avenue, N.W.
Washington, DC20460

Dear Mr. Grumbles,

I am submitting these comments on behalf of the North American Benthological Society (NABS) of which I am the President. NABS is a scientific society with more than 1600 members whose research and professional activities focus on the physical, chemical, and biological structure and function of rivers and streams and other shallow-water ecosystems. The policy of NABS is to promote the use of the best available science for decision-making related to freshwater ecosystems and to communicate this science as necessary to inform the public, environmental managers and decision-makers. These comments have been approved by the Executive Committee of the Society.

The NABS requests that the U.S. Environmental Protection Agency (EPA) recalculate the water quality criteria for ammonia to include freshwater mussel toxicity data. Currently, the ammonia toxicity guidelines (USEPA 1999) are implemented without reference to freshwater mussels; however, since the publication of those guidelines, the scientific literature has firmly established that many of these molluscan species are more sensitive to ammonia than other invertebrates and fishes (Augspurger et al. 2003, Newton 2003). For example, juvenile mussels have an acute EC50 below the ammonia water quality criterion for 24-hour and 48-hour exposures, and they have a lowest-observed effect below the criterion for total ammonia for a 28-day chronic toxicity test. Importantly, new guidelines have recently been published for conducting laboratory toxicity testing with freshwater mussels (ASTM International E2455-06).

As you are likely aware, freshwater mussels are declining at an alarming rate nationwide. Water pollution is considered one of the most important current causes of this decline. Approximately 70% of the nearly 300 mussel species in North America are vulnerable to extinction (72 species are listed as federally threatened or endangered and 35 species are already extinct; Andrew Roberts, U.S. Fish and Wildlife Service, Columbia, MO, personal communication). Therefore it is imperative that the U.S. EPA act quickly to use existing data and revise the ammonia criteria to protect this sensitive and ecologically important aquatic fauna. We also encourage the EPA to promote new studies to verify freshwater mussel protection.

Thank you for your consideration of this important issue.

Sincerely,

N. LeRoy Poff, Ph.D.

President, North American Benthological Society

Department of Biology

ColoradoStateUniversity

Fort Collins, CO80523

970-491-2079

Literature Cited:

ASTM International. E2455-06 “Standard Guide for Conducting Laboratory Toxicity Tests with Freshwater Mussels. [Formerly the American Society for Testing and Materials]

Augspurger, T., A.E. Keller, M.C. Black, W.G. Cope, and F.J. Dwyer. 2003. Water quality guidance for protection of freshwater mussels (Unionidae) from ammonia exposure. Environmental Toxicology and Chemistry 22(11):2569–2575.

Newton, T.J. 2003. The effects of ammonia on freshwater unionid mussels. Environmental Toxicology and Chemistry 22(11):2543–2544.

USEPA (U.S. Environmental Protection Agency). 1999. 1999 Updateof ambient water quality criteria for ammonia. EPA-822-R-99-014. Office of Water, Washington, DC.

cc: American Fisheries Society, Freshwater Mussel Conservation Society, Society of Environmental Toxicology and Chemistry, U.S. Fish and Wildlife Service, U.S. Geological Survey, and Upper Mississippi River Conservation Committee

Sample letter for the blind copies:

Mr. Gus Rassam, Executive Director

American Fisheries Society

5410 Grosvenor Lane, Suite 110

Bethesda, MD20814-2199

Dear Mr. Rassam,

The North American Benthological Society (NABS) encourages the American Fisheries Society to join us in support of freshwater mussel conservation by requesting that the U.S. Environmental Protection Agency (EPA) recalculate the water quality criteria for ammonia to include freshwater mussel toxicity data.

Freshwater mussel data are not included in the current database for calculating the 1999 U.S. EPA water quality criteria for ammonia. Current data indicate that freshwater mussels are more sensitive to ammonia relative to other invertebrates and fishes. Therefore the 1999 U.S. EPA water quality criteria for ammonia are not protective of these important aquatic organisms.

Attached is a copy of the letter that the NABS sent to the U.S. EPA for you reference. The support of the American Fisheries Society is appreciated.

Sincerely,

American Fisheries Society

Mr. Gus Rassam, Executive Director

American Fisheries Society

5410 Grosvenor Lane, Suite 110

Bethesda, MD20814-2199

Freshwater Mollusk Conservation Society

Mr. Robert M. Anderson, President

Freshwater Mussel Conservation Society

U.S. Fish and Wildlife Service
312 South Allen Street, Suite 322
State College, PA16801

Society of Environmental Toxicology and Chemistry

Mr. Paul Goodson, Director

SETAC North America
1010 North 12th Avenue
Pensacola, FL32501-3370

U.S. Geological Survey

Mr. P. Patrick Leahy, Acting Director

U.S. Geological Survey Headquarters

JohnW.PowellFederalBuilding

12201 Sunrise Valley Drive, MS 100

Reston, VA 20192

U.S. Fish and Wildlife Service

Mr. Dale Hall, Director

U.S. Fish and Wildlife Service

Department of Interior, 1849 C Street, NW

Washington, DC 20240

Upper Mississippi River Conservation Committee

Mr. Scott Yess, UMRCC Coordinator

U.S. Fish and Wildlife Service

555 Lester Avenue

Onalaska, WI 54650