memo

To: Tiered Aquatic Life Use Workgroup



From: Susan Jackson 11/5/01

U.S. EPA Biological Criteria Program



Re: Revised Biological Condition Gradient



Attached is the latest version of the draft biological condition gradient - revised to address

written comments from individual workgroup members and specific recommendations from the

workshop in Baltimore last winter. Your review and comment on the revised biological

condition gradient is requested by December 16, 2001. Please email me with a cc to

Dennis McIntyre. You can also pen your comments in the margins of draft documents

and mail them to me at: U.S. EPA, mail code 4304, 1200 Pennsylvania Avenue, Washington

D.C. S.W, 20460. Your comments will be key in setting the agenda for the next workgroup

meeting planned for March, 2002 in the Baltimore-Washington area. The dates for the

workshop are not yet set.



Right up front, I want to acknowledge Susan Davies for her leadership and dedication to this

effort. Additionally, several workgroup members have provided extensive review and comment

on the revisions, including extremely insightful recommendations for tackling tough issues.

These workgroup members include: Susan Norton, Phil Larsen, Bob Hughes, Jan Stevenson,

Mike Barbour, Maggie Passmore, Dave Lenat, Chris Yoder, Dave Courtemanch, Russ

Frydenborg, Ed Hammer and Evan Horning. Additionally, Bill Wuerthele from Region 8 water

Quality Standards Program and LeRoy Poff from Colorado State University have provided

insightful comments and different perspectives on the draft materials.



Biological Condition Gradient - File Index:



Based on the workgroup meeting in Baltimore last year, the draft biological condition gradient

has been revised in both substance and format. What you will notice first is that there are now

several files attached to this email. These documents are in Word and are explained in the text

that follows. These files are:



1. the revised biological condition gradient - file: biologicalconditiongradient



2. narrative summary of the biological condition gradient - file: executivesummary



3. attribute matrix - file: attributematrix



4. background explanation on attributes from Susan Davies - file: attributeexplanation



5. Maine case example - file: mainecaseexample



6. draft definitions - file: definitions



These files are discussed below. Redesign of the workgroup website has not been completed

yet. In the interim, you can access workshop summary notes and presentations at the following

website: http://www.glec_online.com/test/alus2/alus2.htm. Contact Dennis McIntyre (614)

487-1040 if you have trouble accessing the website.



Key Baltimore Workshop Recommendations on Draft Biological Condition Gradient:



There were many specific technical edits and substantive comments from individual workgroup

members and from the workshop recommendations. To the best extent possible, these technical

edits and comments have been incorporated in the current draft. Not all comments may have

been incorporated and some of these comments are discussed below under “outstanding issues”

and remain to be resolved. The main changes to the biological condition axis are discussed

below.



#1. Simplify the biological condition gradient but do not lose the detail. There was a strong

consensus at the workshop that a simplified framework is needed to provide a more systematic

approach to characterizing predicted biological change along the gradient. This is important for

both technical readers (e.g. field biologists) and for managers who need to know how this

framework will fit into and benefit their programs (e.g. water and watershed program managers).

At the Baltimore workshop, the NW Breakout group produced a simplified model for organizing

the biological condition gradient. This framework was the basis for the reorganized format of

the biological condition gradient, the attribute matrix and the resulting executive summary.

The file attribute explanation provides an interpretative context for the attributes in the

biological condition gradient. Additionally, a management framework that links the biological

condition gradient to water quality standards is in draft and will be distributed to the workgroup

next month. See discussion below under “Work in Progress.” The original case example for

Northern temperate streams is now a separate file, maineexample. Additional case examples

representative of different regions will be developed this spring once the condition gradient has

undergone this second round of review and comment.



#2. Even out the magnitude of change in each tier. Another major workshop comment was

the uneveness in change from one tier to another in the original condition gradient. Specifically,

the original top two tiers (formally Tiers A and B) were seen as “too tight” and viewed as

clustered at the high end of the gradient - difficult to distinquish between the two, particularly for

management purposes. The third tier, (formally Tier C) covered too broad a range of change

between the high end of the gradient and the lower two tiers representive of waters in poor

condition (formerly Tiers D and E). Attention and more detail was put to this part of the

condition gradient - the range of biological conditions between “very good” and “poor.”



The condition gradient was revised to address this concern about uneveness in the tiers. The

revised gradient now has 6 tiers identified by numbers 1 through 6 (letters were dropped because

of association with letter grades). Tiers 1 and 2 should equate with the CWA integrity

objective (see outstanding issues discussion below). Tiers 3 and 4 were developed based on

consensus workshop recommendations on what constitutes conditions that meet the CWA goal

for protection and propagation of fish, shellfish and wildlife - the “interim goal.” The intention

of this revision has been to describe Tier 4 to be not significantly different from the former Tier

C biological condition, as agreed upon in Baltimore. The lower two tiers, 5 and 6, represent

conditions that do not meet the interim goal.



#3. Evaluate attainment of the CWA interim goal (protection and propagation of fish, shellfish

and wildlife) to include maintenance of ecosystem function. There was broad support at the

Baltimore workshop that an ecological benchmark for attaining the interim goal for aquatic life

was maintenance of ecosystem function. The revision incorporates this recommendation but

further work is needed to clarify what we are really thinking about here. Currently, State and

Tribal programs are commonly using methods that measure community structure. Information

derived from these measures is then used as surrogates for inferring ecosystem function.

Additionally, teasing out issues of different scale is also a challenge. The workgroup is requested

to review and provide specific comments on how this attribute can be currently measured;

strengths and limitations of any particular method, and pitfalls to avoid. Please refer to the file

attribute explanation for further discussion.



#4. Clarify terminology and provide definitions. Please review and comment on definitions

file. The definition of terms on taxa is context dependent and will ultimately be user defined

(e.g. ecoregion, stressor, sampling method, level of effort i.e. species vs family identification).

For example, the taxa that can be described as sensitive or tolerant will differ depending upon

stressor. Assemblages may have seemingly contradictory responses depending on the stressor

scenario.



Thank you to Dave Courtemanch, Chuck Hawkins and Bob Hughes for contributing definitions.

Also, Doug Norton from the EPA’s watershed program authored an EPA white paper on

non-native species. Definitions from that paper have been included.



Outstanding Issues:



#1. Presence of Non-native species in the highest tier (tier 1). Tier 1 represents “natural”

condition; that is “native structural, functional and taxonomic integrity is preserved”. As

currently drafted, the tier also allows for the presence of non-native species that have no

detrimental effect on native species and where, conceptually, native structure, function and taxa

are not altered. The reason for this is practical - review comments from some workgroup

members strongly recommend making tier 1 an attainable management goal for this gradient to

be fully relevant and implementable in State and Tribal water quality programs. Providing legal

protection for very high quality waters that would be considered pristine except for the

ubiquitous presence of an intentionally introduced species, typically a fish such as brown or

rainbow trout, is considered desirable.



On the other hand, some other workgroup members have recommended that the top tier remain

“pure” and not allow for the presence of any non-native species. The arguement for this

position is equally valid. While recognizing the hypothetical nature of this tier for most if not

all parts of the world, a clean definition, or standard, provides a conceptual anchor for the

biological condition gradient that is not compromised.



#2. Making Allowance for Global Extinctions in Tiers 1 and 2. On a similar vein, the current

tiers 1 and 2 also allow for global extinction. Again, the basis for this is primarily practical - to

provide legal protection for waters that would be considered pristine or near pristine except for

the absence of a globally extinct species.



There is not a right or wrong position on the above issues and workgroup consensus may not be

achievable. You are requested to comment on these two related issues, and, if possible, include

examples that demonstrate key points of your arguement. If a workgroup consensus cannot be

achieved, stating the case for each option is the next step and will be important information to

enable the U.S. EPA make a determination. Ultimately, it is important to clearly communicate

what this gradient is and the underlying rational, so that State and Tribal water programs,

stakeholders and the public clearly understand its strengths and limitations.



#3. Tiers that do not attain the CWA interim goal for aquatic life. Most of the workgroup

discussion to date has focused on characterizing the biological condition tiers that attain the

CWA interim goal for aquatic life, “the protection and propagation of fish, shellfish, and

wildlife”. This tendency is a natural progression - moving our attention from the high end of the

gradient on down the scale. Several workgroup members have identified the need to provide

more definition, perhaps an additional tier, to the part of the gradient that does not meet the

interim goal. This is a practical need for those States and Tribes where degradation due to

human activities is severe and widespread. Incremental, attainable goals for restoring highly

degraded waters are needed. Even if these goals do not meet the CWA interim goal - they are

steps in the right direction. The current lowest tier, tier 6, is seen as dead and not useful as a

management goal. Over the next few months, there will be a focused effort on drafting

revisions to tiers 5 and 6. If you would like to be part of a focus group to prepare a draft for the

full workgroup - please email me.



Key Messages That Need To Be Communicated Loud And Clear:



Effective communication is a priority need - a clear, consistent message about what the gradient

is and what it is not, how it is to be applied, and how to minimize, if not totally avoid,

misunderstandings and misapplications. Your review and comment on communication (e.g.

specific terms that may be misinterpreted, jargon, sweeping generalizations or terms that may

have multiple meanings) is requested. So far, the following key communication themes that

have been identified:



1. The biological condition gradient is conceptual. The purpose of this national

framework is to provide an ecologically-based model for communication of biological condition.

The descriptive, incremental gradient should enable better communication about where goals

could be set and enable a better, more accurate understanding of current conditions. This

should result in more meaningful engagement of the public in goal setting - specifically in the

designation of aquatic life uses in State and Trial water quality standards programs.



2. The conceptual framework is not defined by any one method. The conceptual gradient

is independent of different assessment methodologies (i.e. Rapid Biological Assessment, Index

of Biological Integrity; RIVPACS, etc.). The ecological premise that supports the model should

reflect the same ecological basis that underlies all the methods used to quantify predicted

biological response to increasing human disturbance. Examples of how different

methodological approaches can be applied to this framework will be prepared in next steps upon

completion of this round of review and comment.



3. Number of tiers. The purpose of the number of tiers is to provide a highly resolved

conceptual biological condition gradient. There is no expectation that State or Tribal programs

adopt 6 tiers, or categories, of designated uses. While step wise progress toward refinement of

designated aquatic life uses in State and Tribal water quality standards programs is desired over

the long term, the ultimate number and type of levels of protection is a State or Tribal

determination.



4. The attributes are not a checklist. The list of attributes is intended to organize and record

the current state of our understanding and observations concerning changes in key characteristics

of an aquatic community in response to increasing levels of human disturbance, but it should not

be thought of as a checklist or scorecard. Rather the approach should be thought of as seeking

to identify a “best fit” tier, weighing the importance and signal-strength of the different attributes

as they pertain to a specific waterbody. The listed attributes generally have a quantifiable

aspect that potentially be measured in many different ways. This conceptual model in no way

reduces the necessity of ultimately developing rigorous methods for the quantitative and

statistical validation of relative biological conditions. Comments and recommendations from

the workgroup on such an approach is requested.



Work In Progress:



1. Implementation in State and Tribal Water Quality Standards. A draft management

matrix relating the biological condition gradient to chemical water quality criteria and the water

quality standards program is currently under review by EPA’s water quality standards program.

This draft is based on the example provided by Rich Eskin at the Baltimore workshop. A draft

will be distributed to the workgroup within a month. This matrix will provide the starting point

for drafting program guidance to implement the conceptual framework in water quality

standards. Specific discussions are occurring within the criteria and standards program on the

following:



The relationship between other types of water quality criteria (e.g. chemical, nutrient) and both

the biological condition and human disturbance gradients is also being examined. Members of

the Tiered ALU workgroup are engaging scientists from EPA’s chemical and nutrient water

quality criteria program and research laboratories to work through theses issues. Products from

this effort will include case examples of how other types of water quality criteria fit into both

gradients and will be prepared for the workgroup distribution prior to the workshop planned for

March.



Additionally, the Water Quality Standards Program is engaged in discussion on the application

of the tiered aquatic life framework to use attainability analysis (UAA). A workshop is planned

this week in San Francisco on current approaches and issues in conducting use attainability

analyses. The tiered aquatic life use model will be included in the workshop discussions and

option development. Chris Yoder will be attending the workshop with Jim Keating of EPA’s

Water Quality Standards Program.

2. Additional Case Examples. Two workshops are planned for next spring to further

groundtruth the biological condition gradient and to develop additional case examples for

streams in the central plains and the arid west. These workshops will be modeled after the data

exercises conducted at the Baltimore workshop last year. EPA’s nutrient criteria team intends to

send scientists to these workshops to help internally link our two efforts. Additionally,

preliminary plans are in the works to “road test” the conceptual framework and develop case

examples for large rivers based on the Ohio and the Upper Mississippi Rivers; for depressional

and riparian wetlands; and for estuaries based on Narragansett Bay National Estuary Program.

We welcome suggestions from the workgroup for other opportunities or needs for other case

examples.



3. Human Disturbance Gradient.



A human disturbance gradient has been drafted by Bob Hughes with support from the steering

committee. The human disturbance gradient describes conditions in the environment that range

from natural to severely degraded. It is similar in structure to the biological condition gradient in

that it is divided into a set of tiers with each tier containing a narrative description of water

resource variables and the human activities that affect the water resource variables. Examples

of the water resource variables are, habitat structure, flow regime, water quality, toxic chemicals,

energy source and biotic interactions. The human activities that affect these water resource

variables are landscape character, riparian condition, barriers and channel morphology. A focus

of the next general workgroup meeting will be to groundtruth the human disturbance gradient in

a similar fashion to the biological condition gradient at the Baltimore workshop. A draft will be

distributed to the workgroup for review and comment prior to the next workshop. Target date

for completion of the draft for workgroup review is January.



4. Linkage of Conceptual Framework to Technical Components. A next important step

will be to illustrate how the conceptual model can be implemented in existing State or Tribal

programs; including State programs that may not yet have a comprehensive monitoring program,

long term data base or programs that rely on Family-level taxonomic information. Examples

will include different methodological approaches and different levels of assessment effort. This

information will be an important component of national guidance.



5. Timeframe for completion of workgroup activities. At our first workgroup meeting in

June, 2000, the workgroup was charged with developing recommendations on how to use

biological assessments and criteria to tier designated aquatic life uses in State and Tribal water

quality standards; identify obstacles and pitfalls to avoid; problem solve these issues and develop

solutions. Workgroup recommendations will be used by the U.S. EPA to develop national

guidance. The workgroup made recommendations on the elements of a tiered aquatic life use

approach and the basic outline of a conceptual biological condition gradient at the first

workshop. At our second workgroup meeting last February, a draft biological condition

gradient was evaluated with the attached revisions as a result. Another major component of the

framework, the human disturbance gradient, was introduced and is being prepared for

distribution to the workgroup this winter. Additional components of the guidance that are in

preliminary stages include a management framework and case examples that link the conceptual

model to technical methods and program implementation. The third workgroup meeting,

proposed for March 2002, will finalize the biological condition gradient; groundtruth the draft

human disturbance gradient and management framework. I anticipate one additional workgroup

meeting either in the Fall of 2002 or Spring of 2003 to finalize the human disturbance gradient,

management framework and case examples. We are currently preparing our workplans and

budget for FY2002 which will influence the time for completion of workgroup products.



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