UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
JJN.I9I99J
OFFICE OF
MEMORANDUM . WATCR
SUBJECT: Transmittal of Final (jplicyjon Biological
Assessments and Criteria
FROM: Tudor T. Davies, Director
Office of Science and Technology (WH-551)
..TO.*-.- Water Management Division Directors
Regions I-X
Attached is EPA's "Policy on the Use of Biological
Assessments and Criteria in the Water Quality Program"
(Attachment A). This policy is a significant step toward
addressing all pollution problems within a watershed. It is a
natural outgrowth of our greater understanding of the range of
problems affecting watersheds from toxic chemicals to physical
habitat alteration, and reflects the need to consider the whole
picture in developing watershed pollution control strategies.
This policy is the product of a broad-"based workgroup chaired
by Jim Flafkin and Chris Faulkner of the Office of Wetlands,
Oceans and Watersheds. The workgroup was composed of
representatives from seven EPA Headquarters offices, four EPA
Research Laboratories, all 10 EPA Regions. U.S. Fish and Wildlife
Service, U.S. Forest Service, and the States of New York and
North Carolina (see Attachment B). This policy also reflects
review comments to the draft policy statement issued in March of
1990. Comments were received from three EPA Headquarters
offices, three EPA Research Laboratories, five EPA Regions and
two States. The following sections of this memorandum provide a
brief history of the policy development and additional
information on relevant guidance.
Background
The Ecopolicy Workgroup was formed in response to several
converging initiatives in EPA's national water program. In
September 1987, a major management study entitled "Surface Water
Monitoring: A Framework for Change" strongly emphasized the need
to "accelerate development and application of promising
biological monitoring techniques" in State and EPA monitoring
programs. Soon thereafter, in December 1907. a National Workshop
on Instream Biological Monitoring and Criteria reiterated this
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Veccnmenaarion cut s~so pointed cut the -T.portar.ce cf inteqrating
the biological criteria and assessment methoas with traditional
chemical/physical methods (see Final Proceedings, EPA-905/9- ;.
89/003). Finally, at the June 1988 National Symposium on Water
Quality Assessment, a workgroup of State and Federal
representatives unanimously recommended the development of a
national bioassessment policy that encouraged the expanded use of
the new biological tools and directed their implementation across
the water quality program.
Guided by these recommendations, the workgroup held three
workshop-style meetings between July and December 1988. Two
major questions emerged from the lengthy discussions as issues of
general concern:
ISSUE 1 - How hard should EPA push for formal adoption of
biological criteria (biocriteria) in State
water quality standards?
ISSUE 2 - Despite the, many beneficial uses of
. biomonitoring information, how do we guard
against potentially inappropriate uses of such
^t" ~ .'.".'.':'' data in the permitting process?
Issue 1 turns on the means and relative priority of having
biological criteria formally incorporated in State water quality
standards. Because biological criteria must be related to local.
conditions, the development of quantitative national biological
criteria is not ecologically appropriate. Therefore, the primary
concern is how biological criteria should be promoted and
integrated into State water quality standards.
Issue*2 addresses the question of how to reconcile potential
apparent conflicts in the results obtained from different
assessment methods (i.e., chemical-specific analyses, toxicity
testing, and biosurveys) in a permitting situation. Should the
relevance of each be judged strictly on a case-by-case basis?
Should each method be applied independently?
These issues were discussed at the policy workgroup's last
meeting in November 1988, and consensus recommendations were then
presented to the Acting Assistant Administrator of Water on
December 16, 1988. For Issue 1, it was determined that adapting
biological criteria to State standards has significant
advantages, and adoption of biological criteria should be
strongly encouraged. Therefore, the current Agency Operating
Guidance establishes the State adaptation of basic narrative
biological criteria as a program priority.
With respect to Issue 2, the policy reflects a position of
"independent application." Independent application means that
any one of the three types of assessment information (i.e.,
chemistry, toxicity testing results, and ecological assessment)
provides conclusive evidence of nonattainment of water quality
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standards regardless of the results from other types of
assessment information. Each type of assessment is sensitive to
different types of water quality impact. Although rare, apparent
conflicts in the results from different approaches can occur.
These apparent conflicts occur when one assessment approach
detects a problem to which the other approaches are not
sensitive. .This policy establishes that a demonstration of water
quality standards nonattainment using one assessment method does
not require confirmation with a second method arid that the
failure of a second method to confirm impact does not negate the
results of the initial assessment.
Review of Draft Policy
The draft was circulated to the Regions and States on
March 23, 1990. The comments were mostly supportive and most of
the suggested changes have been incorporated. Objections were
raised by one State that using ecological measures would increase
the magnitude of the pollution control workload. We expect that
this will be one result of this policy but that our mandate under
the Clean Water Act to ensure physical, chemical, and biological'
integrity requires that we adopt this policy. Another State
objected to the independent application policy. EPA has
carefully considered the merits of various approaches to
integrating data in light of the available data, and we have
concluded that independent application is the most appropriate
policy at this time. Where there are concerns that the results
from one approach are inaccurate, there may be opportunities to
develop more refined information, that would provide a more
accurate conclusion (e.g., better monitoring or more
sophisticated wasteload allocation modelling).
Additional discussion on this policy occurred at the Water.
Quality Standards for the 21st Century Symposium in December,
1990.
What Actions Should States Take
This policy does not require specific actions on the part, of
the States or the regulated community. As indicated under the
Fiscal Year 1991 Agency Operating Guidance, States are required
to adopt narrative biocriteria at a minimum during the 1991 to
1993 triennial review. More specific program guidance on
developing biological criteria is scheduled to be issued within
the next few months. Technical guidance documents on developing
narrative and numerical biological criteria for different types
of aquatic systems are also under development.
Relevant Guidance
There are several existing EPA documents which pertain to
biological assessments and several others that are currently
under development. Selected references that are likely to be
important in implementing this policy are listed in Attachment C.
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Please share this policy statement with your States and work
with them to institute its provisions. If you have any
questions, please call me at (FTS) 382-5400 or have your staff
contact Geoffrey Grubbs of the Office of Wetlands, Oceans and
Watersheds at (FTS) 382-7040 or Bill Diamond of the Office of
Science and Technology at (FTS) 475-7301.
Attachments
cc: OW Office Directors
Environmental Services Division Directors, Regions I-X
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Attachment A
Policy on the Use of Biological Assessments and Criteria
in the Water Quality Program
May 1991
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Contents
Statement of Policy
Definitions
Background
Context of Policy
Rationale for Conducting Biological Assessments
Conduct of Biological Surveys
Integration of Methods and Regulatory Application
Site-specific Considerations
Independent Application
Biological Criteria
Statutory Basis
Section 303(c)
Section 304(a)
State/EPA Roles in Policy Implementation
State Implementation
EPA Guidance and Technical Support
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Statement of Policy
To help restore and maintain the biological integrity of the Nation's
waters, it is the policy of the Environmental Protection Agency (EPA) that
biological surveys shall be fully integrated with toxicity and chemical-specific
assessment methods in State water quality programs. EPA recognizes that
biological surveys should be used together with whole-effluent and ambient
toxicity testing, and chemical-specific analyses to assess attainmcnt/nonattainment
of designated aquatic life uses in State water quality standards. EPA also
recognizes that each of these three methods can provide a valid assessment of
designated aquatic life use impairment. Thus, if any one of the three assessment
methods demonstrate that water quality standards arc not attained, it is EPA's
policy that appropriate action should be taken to achieve attainment, including
use of regulatory authority.
It is also EPA's policy that States should designate aquatic life uses that
appropriately address biological integrity and adopt biological criteria necessary to
protect those uses. Information concerning attainmcnt/nonattainment of standards
should be used to establish priorities, evaluate the effectiveness of controls, and
make regulatory decisions.
Close cooperation among the States and EPA will be needed to carry out
this policy. EPA will provide national guidance and technical assistance to the
States; however, specific assessment methods and biological criteria should be
adopted on a State-by-State basis. EPA, in its oversight role, will work with the
States to ensure that assessment procedures and biological criteria reflect
important ecological and geographical differences among the Nation's waters yet
retain national consistency with the Clean Water Act.
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Definitions
Ambient Toxicitv: Is measured by a toxicity test on a sample collected from a
waterbody.
Aquatic Community: An association of interacting populations of aquatic
organisms in a given waterbody or habitat.
Aquatic Life Use: Is the water quality objective assigned to a waterbody to
ensure the protection and propagation of a balanced, indigenous aquatic
community.
Biological Assessment: An evaluation of the biological condition of a waterbody
using biological surveys and other direct measurements of resident biota in
surface waters.
Biological Criteria (or Biocritcria): Numerical values or narrative expressions that
describe the reference biological integrity of aquatic communities inhabiting waters
of a given designated aquatic life use.
BioloEical Integrity: Functionally defined as the condition of the aquatic
community inhabiting unimpaired waterbodics of a specified habitat as measured
by community structure and function.
Biological Monitoring: Use of a biological entity as a detector and its response
as a measure to determine environmental conditions. Toxicity tests and
biosurveys are common biomonitoring methods.
Biological Survey (or Biosurvcv): Consists of collecting, processing, and analyzing
a representative portion of the resident aquatic community to determine the
community structure and function.-
Communitv Component: Any portion of a biological community. The
community component may pertain to the taxoromic group (fish, invertebrates,
algae), the taxonomic category (phylum, order, family, genus, species), the feeding
strategy (herbivore, omnivore, carnivore), or organizational level (individual,
population, community association) of a biological entity within the aquatic
community.
Habitat Assessment: An evaluation of the physical characteristics and condition
of a waterbody (example parameters include the variety and quality of substrate,
hydrological regime, key environmental parameters and surrounding land use.)
Toxicitv Test: Is a procedure to determine the toxicity of a chemical or an
effluent using Jiving organisms. A toxicity test measures the degree of response
of exposed test organisms to a specific chemical or effluent.
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Whole-effluent Toxicitv: Is the total toxic effect of an effluent measured directly
with a toxicity test.
Background
Policy context
Monitoring data are applied toward water quality program needs such as
identifying water quality problems, assessing their severity, and setting planning
and management priorities for remediation. Monitoring data should also be used
to help make regulatory decisions, develop appropriate controls, and evaluate the
effectiveness of controls once they are implemented. This policy focuses on the
use of a particular type of monitoring information that is derived from ambient
biosurveys, and its proper integration with chemical-specific analyses, toxicity
testing methods, and biological criteria in State water quality programs.
The distinction between biological surveys, assessment'; and criteria is an
important one. Biological surveys, as stated in the section above, consist of the
collection and analysis of the resident aquatic community data and the
subsequent determination of the aquatic community's structure and function. A
biological assessment is an evaluation of the biological condition of a waterbody
using data gathered from biological surveys or other direct measures of the biota.
Finally, biological criteria are the numerical values or narrative expressions used
to describe the expected structure and function of the aquatic community.
Rationale for Conducting Biological Assessments
To more fully protect aquatic habitats and provide more comprehensive
assessments of aquatic life use attainment/nonattainmcnt, EPA expects States to
fully integrate chemical-specific techniques, toxicity testing, biological surveys and
biological criteria into their water quality programs. To date, EPA's activities
have focused on the interim goal of the Clean Water Act (the Act), stated in
Section 101(a)(2): To achieve; "...wherever attainable, an interim goal of water
quality which provides for protection and propagation of fish, shellfish, and
wildlife and provides for recreation in and on the water...." However, the
ultimate objective of the Act, stated in Section 101 (a), goes further. Section
101(a) states: "The objective of this Act is to restore and maintain the chemical,
physical, and biological integrity of the Nation's waters." Taken together,
chemical, physical, and biological integrity define the overall ecological integrity of
an aquatic ecosystem. Because biological integrity is a strong indicator of overall
ecological integrity, it can serve as both a meaningful goal and a useful measure
of environmental status that relates directly to the comprehensive objective of the
Act.
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Deviations from, and threats to, biological integrity can he estimated
indirectly or directly. Traditional measures, such as chemical-specific analyses
and toxicity tests, are indirect estimators of biological conditions. They assess
the suitability of the waters to support a healthy community, but they do not
directly assess the community itself. Biosurveys arc used to directly evaluate the
overall structural and/or functional characteristics of the aquatic community.
Water quality programs should use both direct and indirect methods to assess
biological conditions and to determine attainmcnt/nonattainment of designated
aquatic life uses.
Adopting an integrated approach to assessing aquatic life use
attainment/nonattainment represents the next logical step in the evolution of the
water quality program. Historically, water quality programs have focused on
evaluating the impacts of specific chemicals discharged from discreet point
sources. In 1984, the program scope was significantly broadened to include a
combination of chemical-specific and whole-effluent toxicity testing methods to
evaluate and predict the biological impacts of potentially toxic mixtures in
wastewater and surface waters. Integration of these two indirect measures of
biological impact into a unified assessment approach has been discussed in detail
in national policy (49 FR 9016) and guidance (EPA-440/4-85-032). This
approach has proven to be an effective means of assessing and controlling toxic
pollutants and whole-effluent toxicity originating from point sources.
Additionally, direct measures of biological impacts, such as biosurvcy and
bioassessment techniques, can be useful for regulating point sources. However,
where pollutants and pollutant sources are difficult to characterize or aggregate
impacts are difficult to assess (e.g., where discharges arc multiple, complex, and
variable.; where point and nonpoint sources arc both potentially important; where
physical habitat is potentially limiting), direct measures of ambient biological
conditions are also needed.
Biosurveys and biological criteria add this needed dimension to assessment
programs because they focus on the resident community. The effects of multiple
stresses and pollution sources on the numerous biological components of resident
communities are integrated over a relatively long period of time. The community
thus provides a useful indicator of both aggregate ecological impact and overall
temporal trends in the condition of an aquatic ecosystem. Furthermore,
biosurveys can detect aquatic life impacts that other available assessment methods
may miss. Biosurveys detect impacts caused by: (1) pollutants that are difficult
to identify chemically or characterize lexicologically (e.g., rare or unusual toxics
[although biosurveys cannot themselves identify specific toxicants causing toxic
impact], "clean* sediment, or nutrients); (2) complex or unanticipated exposures
(e.g.i combined point and non-point source loadings, storm events, spills); and
perhaps most importantly, (3) habitat degradation (e.g., channelization,
sedimentation, historical contamination), which disrupt the interactive balance
among community components.
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Biosurveys and biological criteria provide important information for a wide
variety of water quality program needs. This data could be used to:
o Refine use classifications among different types of aquatic ecosystems
(e.g., rivers, streams, wetlands, lakes, estuaries, coastal and marine
waters) and within a given type of use category such as warm water
fisheries;
o Define and protect existing aquatic life uses and classify Outstanding
National Resource Waters under State antidcgradation policies as
required by the Water Quality Standards Regulation (40 CFR
131.12);
o Identify where site-specific criteria modifications may be needed to
effectively protect a waterbody;
o Improve use-attainability studies;
o Fulfill requirements under Clean Water Act Sections 303(c), 303(d),
304(1), 305(b), 314, and 319;
o Assess impacts of certain nonpoint sources and, together with
chemical-specific and toxicity methods, evaluate the effectiveness of
nonpoint source controls;
o Develop management plans and conduct monitoring in estuaries of
national significance under Section 320;
o Monitor the overall ecological effects of regulatory actions under
Sections 401, 402, and 301(h);
o Identify acceptable sites for disposal of dredge and fill material
under Section 404 and determine the effects of that, disposal;
o Conduct assessments mandated by other statutes (e.g.,
CERCLA/RCRA) that pertain to the integrity of surface waters;
and
o Evaluate the effectiveness and document the instrcam biological
benefits of pollution controls.
Conduct of Biological Surveys
As is the case with all types of water quality monitoring programs,
biosurveys should have clear data quality objectives, use standardized, validated
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laboratory and field methods, and include appropriate quality assurance and
quality control practices. Biosurveys should be tailored to the particular type of
watcrbody being assessed (e.g., wetland, lake, stream, river, estuary, coastal or
marine water) and should focus on community components and attributes that
are both representative of the larger community and arc practical to measure.
Biosurveys should be routinely coupled with basic physicochemieal measurements
and an objective assessment of habitat quality. Due to the importance of the
monitoring design and the intricate relationship between the biosurvey and the
habitat assessment, well-trained and experienced biologists are essential to
conducting an effective biosurvey program.
Integration of Assessment Methods and Regulatory Application
Site-specific Considerations
Although biosurveys provide direct information for assessing biological
. integrity, they may not always provide the most accurate or practical measure of
water quality standards attainment/nonattainmcnt. For example, biosurveys and
measures of biological integrity do not directly assess nonaquatic life uses, such
as agricultural, industrial, or drinking water uses, and may not predict potential
impacts from pollutants that accumulate in sediments or tissues. These
pollutants may pose a significant long-term threat to aquatic organisms or to
humans and wildlife that consume these organisms, but may only minimally alter
the structure and function of the ambient community. Furthermore, biosurveys
can only indicate the presence .of an impact; they cannot directly identify the
stress agents causing that impact. Because chemical-specific and toxicity methods
are designed to detect specific stressors, they arc particularly useful for diagnosing
the causes of impact and for developing source controls. Where a specific
chemical or toxicity is likely to impact standards attainmcnt/nonattainmcnt,
assessment methods that measure these stresses directly arc often needed.
Independent Application
Because biosurvey, chemical-specific, and toxicity testing methods have
unique as well as overlapping attributes, sensitivities, and program applications,
no single approach for detecting impact should be considered uniformly superior
to any other approach. EPA recognizes that each method can provide valid and
independently sufficient evidence of aquatic life use impairment, irrespective of
any evidence, or lack of it, derived from the other two approaches. The failure
of one method to confirm an impact identified by another method would not
negate the results of the initial assessment. This policy, therefore, states that
appropriate action should be taken when any one of the three types of
assessment determines that the standard is not attained. States arc encouraged
to implement and integrate all three approaches into their water quality programs
and apply them in combination or independently as site-specific conditions and
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assessment objectives dictate.
In cases where an assessment result is suspected to be inaccurate, the
assessment may be repeated using more intensive and/or accurate methods.
Examples df Indre intensive assessment methods are dynamic modelling instead of
steady state modelling, site specific criteria, dissolved metals analysis, and a more
complete biosurvey protocol.
Biological Criteria
To better protect the integrity of aquatic communities, it is EPA's policy
that States should develop and implement biological criteria in their water quality
standards.
Biological criteria are numerical measures or narrative descriptions of
biological integrity. Designated aquatic life use classifications can also function
as narrative biological criteria. When formally adopted into State standards,
biological criteria and aquatic life use designations serve as direct, legal endpoints
for determining aquatic life use attainment/nonattainmcnt. Per Section
131.11(b)(2) of the Water Quality Standards Regulation (40 CFR Part 131),
biological criteria can supplement existing chemical-specific criteria and provide an
alternative to chemical-specific criteria where such criteria cannot be established.
Biological criteria can be quantitatively developed by identifying unimpaired
or least-impacted reference waters that operationally represent best attainable
conditions. EPA recommends States use the ccoregion concept when establishing
a list of reference waters. Once candidate references arc identified, integrated
assessments are conducted to substantiate the unimpaired nature of the reference
and to characterize the resident community. Biosurvcys cannot fully characterize
the entire aquatic community and all its attributes. Therefore, State standards
should contain biological criteria that consider various components (e.g., algae,
invertebrates, fish) and attributes (measures of structure and/or function) of the
larger aquatic community. In order to provide maximum protection of surface
water quality, States should continue to develop water quality standards
integrating all three assessment methods.
Statutory Basis
Section 303(c)
The primary statutory basis for this policy derives from Section 303 of the
Clean Water Act. Section 303 requires that States adopt standards for their
waters and review and revise these standards as appropriate, or at least once
every three years. The Water Quality Standards Regulation (40 CFR 131)
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requires that such standards consist of the designated uses of the waters
involved, criteria based upon such uses, and an antidcgradation policy.
Each State develops its own use classification system based on the generic
uses cited in the Act (e.g., protection and propagation of fish, shellfish, and
wildlife). States may also subcategorize types of uses within the Act's general
use categories. For example, aquatic life uses may be subcatcgorizcd on the
basis of attainable habitat (e.g., cold- versus warm-water habitat), innate
differences in community structure and function (e.g., high versus low species
richness or productivity), or fundamental differences in important community
components (e.g., warm-water fish communities naturally dominated by bass
versus catfish). Special uses may also be designated to protect particularly
unique, sensitive or valuable aquatic species, communities, or habitats.
Each State is required to "specify appropriate water uses to be achieved
and protected" (40 CFR 131.10). If an aquatic life use is formally adopted for
a waterbody, that designation becomes a formal component of the water quality
standards. Furthermore, nonattainment of the use, as determined with either
biomonitoring or chemical-specific assessment methods, legally constitutes
nonattainment of the standard. Therefore, the more refined the use designation,
the more precise the biological criteria (i.e., the more detailed the description of
desired biological attributes), and the more complete the chemical-specific criteria
for aquatic life, the more objective the assessment of standards
attainment/nonattainment.
Section 304(a)
Section 304(a) requires EPA to develop and publish criteria and other
scientific information regarding a number of watcr-quality-rclatcd matters,
including: '
o Effects of pollutants on aquatic community components ("Plankton,
fish, shellfish, wildlife, plant life...") and community attributes
("diversity, productivity, and stability...*);
o Factors necessary "to restore and maintain the chemical, physical,
biological integrity, of all navigable waters...", and "for protection and
propagation of shellfish, fish, and wildlife for classes and categories
of receiving waters...";
o Appropriate 'methods for establishing and measuring water quality
criteria for toxic pollutants on other bases than pollutant-by-pollutant
criteria, including biological monitoring and assessment methods."
This section of the Act has been historically cited as the basis for
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publishing national guidance on chemical-specific criteria for aquatic life, but is
equally applicable to the development and use of biological monitoring and
assessment methods and biological criteria.
State/EPA Roles in Policy Implementation
State Implementation
Because there are important qualitative differences among aquatic
ecosystems (streams, rivers, lakes, wetlands, estuaries, coastal and marine waters),
and there is significant geographical variation even among systems of a given
type, no single set of assessment methods or numeric biological criteria is fully
applicable nationwide. Therefore, States must take the primary responsibility for
adopting their own standard biosurvey methods, integrating them with other
techniques at the program level, and applying them in appropriate combinations
on a case-by-case basis. Similarly, States should develop their own biological-
criteria and implement them appropriately in their water quality standards.
EPA Guidance and Technical Support
EPA will provide the States with national guidance on performing
technically sound biosurveys, and developing and integrating biological criteria
into a comprehensive water quality program. EPA will also supply guidance to
the States on how to apply ecorcgional concepts to reference site selection. In
addition, EPA Regional Administrators will ensure that each Region has the
capability to conduct fully integrated assessments and to provide technical
assistance to the States.
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Attachment c
Relevant Guidance
Chemical-specific evaluations
Guidance for Deriving National Water Quality
Criteria for the Protection of Aquatic Organisms
and Their Uses (45 FR 79342, November 28, 1990, as
amended at 50 FR 30784, July 29, 1985)
Quality Criteria for Water 1986 (EPA 440/5-86-001,
May 1, 1987)
Toxicity testing
Short-Term Methods for Estimating the Chronic
Toxicity of Effluents and Receiving Waters to
Freshwater Organisms, Second Edition (EPA/600-4-
89-001) , March 1989)
Short-Term Methods for Estimating the Chronic
Toxicity of Effluents and Receiving Waters to
Marine and Estuarine Organisms (EPA/600-4-87/028,
May 1988)
Methods for Measuring Acute Toxicity of Effluents
to Freshwater and Marine Organisms (EPA/600-4-85-
013, March 1985)
Biosurveys and integrated assessments
Technical Support Manual: Waterbody Surveys and
Assessments for Conducting Use Attainability
Analyses: Volumes I-Ill (Office of Water
Regulations and Standards, November 1983-1984)
Technical Support Document for Water Quality-based
Toxics Control (EPA/505/2-90/001, March 1991)
Rapid Bioassessment Protocols for Streams and
Rivers: Benthic Macro-invertebrates and Fish
(EPA/444-4-89-001, May 1989)
Hughes, Robert M. and David P. Larsen. 1988.
Ecoregions: An Approach to Surface Water
Protection. Journal of the Water Pollution
Control Federation 60, No. 4: 486-93.
Omerik, J.M. 1987. Ecoregions of the coterminous
United States. Annals of the Association of
American Geographers 77, No. 1: 118-25.
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Regionalization as a Tool for Managing
Environmental Resources (EPA/600-3-89-060, July
1989)
'EPA Biological Criteria - National Program
Guidance for Surface Waters (EPA/440-5-90-004,
April 1990)
being developed
Technical Guidance on the Development of
Biological Criteria
State Development of Biological Criteria (case
studies of State implementation)
Monitoring Program Guidance
Sediment Classification Methods Compendium
Macroinvertebrate Field and Laboratory Manual .for
Evaluating the Biological Integrity of Surface
Waters
Pish Field and Laboratory Manual for Determining
the Biological Integrity of Surface Waters
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