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\	UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

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NOV 1 5 2010

OFFICE OF
WATER

MEMORANDUM

SUBJECT:
FROM:

TO:

Integrated Reporting and Listing Decisionsj^jelatc^f to Ocean Acidification

Denise Keehner, Director	_ '

Office of Wetlands, Oceansimd Watersheds

Water Division Directors, Regions 1-10

The purpose of this Memorandum is to provide information to assist the Regions and States in
preparing and reviewing Integrated Reports related to ocean acidification (OA) impacts under
Sections 303(d), 305(b), and 314 of the Ciean Water Act (CWA). You may recall that EPA
settled a lawsuit in which the Center for Biological Diversity (CBD) challenged EPA's approval
ot Washington State's 2008 CWA 303(d) list, arguing failure to include coastal waters as
impaired for marine pH [CBD v. EPA, No. 2:09-cv-00670-JCC (W. D. Wash.)]. One of the
conditions of the settlement agreement was that EPA would issue this Memorandum by
November 15, 2010, describing how EPA will proceed with regard to the interplay between OA
and the 303(d) program. This Memorandum recognizes the seriousness of aquatic life impacts
associated with OA and describes how States can move forward, where OA information exists,
to address OA during the 2012 listing cycle using the current 303(d) integrated Reporting (IR)
framework. At the same time, this Memorandum also acknowledges and recognizes that in the
case of OA, information is largely absent or limited at this point in time to support the listing of
waters for OA in many States.

I. Background

Ocean acidification refers to the decrease in the pH of the Earth's oceans caused by the uptake of
carbon dioxide, a greenhouse gas (GHG), from the atmosphere. Ocean acidification, like climate
change, is primarily caused by increasing carbon dioxide (CO2) concentrations in the
atmosphere. As a result of absorbing large quantities of human-made CO2 emissions, ocean
chemistry is changing, which is likely to negatively affect important marine ecosystems and
species including coral reefs, shellfish, and fisheries. In addition, OA could cause these
ecosystems to become even more vulnerable to other environmental impacts, especially those
from climate change, such as increases in sea surface temperatures (NRC 2010; Ridgwell and
Schmidt 2010; US EPA 2009b, 2010c; NO A A 2008; Hoegh-Guldberg et al. 2007).

EPA's actions under the Clean Air Act (CAA) to better understand and address the
environmental impacts associated with greenhouse gas (GHG) emissions, including OA and
climate change, currently show the greatest promise in addressing these serious environmental

Internet Address (URL) • http://www.epa.gov
Recycled/Recyclable • Printed with Vegetable Oil Based Inks on 100% Postconsumer, Process Chlorine Free Recycled Paper

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challenges. For example, under the CAA, EPA finalized the Mandatory Reporting of
Greenhouse Gases rule, thereby creating a GHG reporting program to collect comprehensive,
nationwide emissions data; issued the Endangerment and Cause or Contribute Findings for
Greenhouse Gases under Section 202(a) of the CAA; and developed several GHG mitigation
regulations for light-, medium-, and heavy-duty vehicles and for new and existing industrial
facilities that substantially increase GHG emissions. At the same time, EPA also recognizes that
the 303(d) program under the CWA has the potential to complement and aid in these efforts by
ensuring that, over time, we continue to identify and track waters that are impaired due to OA.

II. Summary of Federal Register Notice and Comments Received

EPA published a Federal Register (FR) notice on March 22, 2010, requesting public comment on
what considerations EPA should take into account when deciding how to address the listing of
waters as threatened or impaired by OA under the CWA section 303(d) program, including how
to develop Total Maximum Daily Loads (TMDLs) for such listed waters. The 60-day comment
period on the FR notice ended on May 21, 2010, and resulted in approximately 30,000 responses,
the majority of which were form letters expressing general support for EPA to take immediate
action regarding OA (EPA Docket ID No. OW-20I0-0175, at http://www.regulations.gov).
About 35 individual responses (from State Agencies, environmental non-governmental
organizations, academia, industry, and representatives from Congress) provided the Agency with
detailed comments and recommendations on OA and the 303(d) program. Many commenters
indicated their support for EPA to take both short and long-term action to address OA under the
CWA. Several commenters indicated that the natural daily and seasonal variability of marine pH
makes it difficult to implement the criteria. Other commenters suggested using modeling
methods to identify a baseline for marine pH and recommended that States consider monitoring
for other OA parameters besides marine pH (e.g., dissolved inorganic carbon [DIC], partial
pressure of C02 [pCO;], and/or total alkalinity [TA]) to better reflect OA impacts.

A number of commenters stated that although evaluating OA impacts is challenging, some
monitoring technologies do exist and are available through other programs and academic
institutions. Several commenters indicated that States need detailed guidance and resources to
develop and implement consistent and comprehensive State monitoring and assessment programs
for marine pH criteria and other biological endpoints that reflect adverse OA impacts. A number
of commenters stated that warm water coral reefs were particularly vulnerable to OA, and that
some technical methods exist to help States develop coral reef biological criteria as another way
to protect coastal waters from OA impacts. Other commenters suggested that States can
coordinate and leverage existing Federal and other water sampling programs as they develop
their OA monitoring and assessment methodologies. Several commenters indicated that EPA
should not address OA at all under the CWA, but defer to the CAA to identify and manage CO2
emissions that lead to OA. A few commenters stated that even if waters were listed for OA
impairment, it would be extremely difficult to develop OA-related carbon TMDLs because of the
lack of available methods and data.

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III. Additional Information on Ocean Acidification

After the FR notice comment period closed, EPA evaluated additional information, programs,
and resources to consider how to approach OA under the 303(d) program, which are briefly
described below:

(1)	National Research Council (NRC) Report: At the request of the U.S. Congress, the NRC
published a report titled, "Ocean Acidification: A National Strategy to Meet the Challenges of a
Changing Ocean", the goal of which wras to review the current state of knowledge and identify
key gaps in information to help Federal agencies develop a program to improve OA
understanding and address the consequences of OA (NRC 2010). Overall, the report concludes
that OA science is complex and in its early stages, but that there is evidence that it is a growing
problem which will intensify with continued CO2 emissions, and will adversely affect marine
ecosystems such as marine fisheries, shellfish harvests, and coral reefs. The report states that a
national comprehensive monitoring and assessment network does not exist to establish baselines
for OA parameters (including marine pH) needed to adequately evaluate OA effects, but a
number of current sites and surveys are available to serve as a backbone for a national OA
observational network. The report also states that chemical parameters and methods for OA are
well-established, but not for biological metrics. In addition, the report indicates that existing
knowledge of natural baselines for marine pH is limited because many data sets lack sufficient
monitoring details to be useful in estimating trends. The NRC also suggests other chemical
parameters be monitored along with marine pH to more accurately reflect OA impacts (e.g.,
pCOz, DIC, TA). Finally, the NRC recommends that the Federal government establish a
National OA Program for understanding and responding to OA.

(2)	Future Federal Action: Ocean Acidification has emerged as a top priority within various
Federal efforts. The following are two key actions addressing scientific and technical OA issues,
and in turn, should provide useful OA information for the 303(d) program:

(a)	The National Ocean Council (NOC): On July 19,2010, President Obama issued Executive
Order (EO) 13547 that establishes the Nation's first comprehensive National Ocean Policy for
the stewardship of the ocean, our coasts, and the Great Lakes (Obama 2010). The EO created an
interagency National Ocean Council with the intent to strengthen ocean governance and provide
sustained, high-level focus on the national priority action objectives to advance the National
Policy (available at http://www.whitehouse.gov/administration/eop/oceans). The NOC is
charged with developing Strategy Action Plans for nine priority objectives, including "Climate
Change Adaptation and Ocean Acidification". Upon approval by the NOC, these 2011 action
plans will guide Federal government-wide implementation of ocean policy-related activities and
budgets, including development of a flexible framework for effective coastal and marine spatial
monitoring and planning.

(b)	The Interagency Working Group on Ocean Acidification: The Federal Ocean Acidification
Research and Monitoring (FOARAM) Act of 2009 directed the Joint Subcommittee on Science
and Technology (JSOST) to create an Interagency Working Group on Ocean Acidification
(IWG-OA) to coordinate OA activities across Federal agencies. This Interagency Committee, in
which EPA participates, is responsible for organizing and expanding research programs with the

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following goals: to enhance understanding of the role of OA on marine ecosystems, identify
marine ecosystem conservation measures, facilitate information exchange on OA methods, and
investigate the socioeconomic impacts of OA. The IWG-OA is drafting a strategic research plan
tor OA, to be completed in 2011. An initial report on the plan's progress, including a summary
of existing Federally-funded OA research and monitoring activities, including their budgets, was
recently completed (IWG-OA 2010).

(3) OA Criteria: Currently all 23 coastal States and five Territories (hereafter referred to as
"States'") have marine pH water quality criteria (WQC) in place that are similar to EPA's CWA
304(a)(1) recommended national criterion: "pH range of 6.5 to 8.5 for marine aquatic life, but
not varying more than 0.2 units outside of the normally occurring range." In addition, more than
half the States have coastal monitoring programs. Although EPA recently approved Puerto
Rico's 2010 303(d) list that included five waters impaired by marine pH, the majority of the
States do not have detailed monitoring protocols, assessment methods, or the high-resolution
equipment needed to measure and implement the marine pH criteria. In particular, in most
coastal regions data are not readily available to characterize short-term marine pH diurnal and
seasonal variability, or to quantify a normally occurring pH "baseline" necessary to identify
variation from natural and any long term trends (NRC 2010). After reviewing a wide range of
information received in response to a Notice of Data Availability (NODA) on Ocean
Acidification and Marine pH Water Quality Criteria (US EPA 2009c), EPA decided against
revising the national marine pH criterion for aquatic life due to insufficient data (US EPA
2010b). Finally, only a handful of States have WQC for other OA parameters (e.g., dissolved
gases, including CO2), and most are not actively monitoring for these parameters. A few States
have narrative or numeric biocriteria for marine waters with coral reefs that could reflect OA
impacts. States will need to continue to use their current marine pH criteria as a basis for 303(d)
listing until additional OA criteria are adopted.

IV. Decision Regarding OA and 303(d) Program

EPA has carefully reviewed and considered information received from public comments, other
Federal OA programs, and additional scientific information available on this issue in deciding
how to approach OA under the 303(d) program. EPA has concluded that States should list
waters not meeting water quality standards, including marine pH WQC, on their 2012 303(d)
lists, and should also solicit existing and readily available information on OA using the current
303(d) listing program framework. This Memorandum does not elevate in priority the
assessment and listing of waters for OA, but simply recognizes that waters should be listed for
OA when data are available. EPA recognizes that information is absent or limited for OA
parameters and impacts at this point in time and, therefore, listings for OA may be absent or
limited in many States.

EPA will provide additional 303(d) guidance to the States when future OA research efforts
provide the basis for improved monitoring and assessment methods, including approaches being
developed under two significant Federal efforts (NOC and IWG-OA, described above) that will
begin in early 2011. This future OA guidance may be in the form of stand-alone OA IR
guidance, or as part of EPA's routine, biennial IR update. EPA also encourages States to focus
their efforts on OA-vulnerable waters (e.g., waters with coral reefs, marine fisheries, shellfish

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resources) that already are listed for other pollutants (e.g., nutrients) in order to promote
ecological restoration.

V. Closing Information

Thank you for your continued hard work and dedication working with our States to develop
Integrated Reports. This Memorandum and Attachment are consistent with previous IR
guidance, and the current statutory framework under CWA Sections 303(d), 305(b), and 314.
They are not regulations, do not impose legally binding requirements on EPA or the States, and
do not require States to develop any new 303(d) program related to OA. If you have any
questions or comments concerning this Memorandum, please contact me or have your staff
contact John Goodin at 202-566-1373 (goodin.john@epa.gov) or Christine Ruf at 202-566-1220
(ruf.christine@epa.gov) in the Office of Wetlands, Oceans and Watersheds.

Attachment

cc: US EPA Regional Section 303(d) Coordinators
US EPA Regional Monitoring Coordinators
Brian McLean, Director, Office of Atmospheric Programs, OAR
Alexandra Dunn, ASIWPCA

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ATTACHMENT: INFORMATION CONCERNING 2012 CLEAN WATER ACT
SECTIONS 303(d), 305(b), AND 314 INTEGRATED REPORTING AND LISTING
DECISIONS RELATED TO OCEAN ACIDIFICATION

This Attachment describes how States can move forward to address ocean acidification (OA)
during the 2012 listing cycle using the current 303(d) Integrated Reporting (IR) framework.
EPA reaffirms that States must list waters not meeting water quality standards where data and
assessment methods are available, including marine pH, but recognizes that information is absent
or limited for OA parameters and impacts at this point in time in many States. EPA will provide
additional 303(d) guidance to the States when future OA research efforts provide the basis for
improved monitoring and assessment methods, including approaches being developed under
significant Federal efforts that will begin in early 2011. This future OA guidance may be in the
form of stand-alone OA IR guidance, or as part of EPA's routine, biennial IR update. The
information in this Attachment is consistent with previous IR Guidance, the current statutory and
regulatory framework under CWA Sections 303(d), 305(b), and 314, and implementing
regulations at 40 CFR 130.7, 130.2, and 130.8. This Attachment is not a regulation, does not
impose legally binding requirements on EPA or the States, and does not require States to develop
any new 303(d) program related to OA.

EPA recommends that States address OA during the 2012 303(d) listing cycle by using key
components from the existing IR Guidance, described below.

1. Data Solicitation Related to Ocean Acidification

EPA recommends that States with marine waters include as part of their routine IR data request,
a provision that solicits existing and readily available water quality-related data and information,
including modeling and other non-site-specific data, for marine pH and natural background
conditions (see below). Scientific guidance documents on methods for monitoring OA have
been published over the last five years. States should refer to NRC's 2010 Report on OA, which
provides technical and scientific information on these methods. In addition, States should
consider requesting data and information on other OA-related parameters recommended by the
NRC, including measurements of temperature, salinity, oxygen, nutrients critical to primary
production, and at least two of the following four carbon parameters: dissolved inorganic carbon
(DIC), partial pressure of carbon dioxide (pCOi), total alkalinity (TA), and pH (NRC 2010).
Several coastal States currently are monitoring for some of these recommended parameters even
in the absence of associated water quality criteria (WQC).

EPA also recommends States specifically solicit existing and readily available biological data
that could be used to make OA attainment decisions based on narrative or numeric biocriteria,
including biological information related to resources that are particularly vulnerable to OA, such
as waters with coral reefs (see section 4, below), marine fisheries, or shellfish resources. EPA
acknowledges that existing and readily available chemical and biological data and information
may be limited to fully assess coastal waterbody impairment due to OA, but the Agency expects
additional data and information will become available in the future. States should refer to
Section IV of EPA's 2006 IR Guidance, "Issues Concerning the Development and Use of an
Assessment Methodology" (US EPA 2005). for specific recommendations regarding overall data

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solicitation and development of assessment methodologies to support State 303(d) attainment
decisions.

Listed below are some monitoring programs that include data that may be useful to States as they
assess coastal waters for marine pH impairment:

A.	NOAA- National Estuarine Research Reserve System (NERRS): Website contains real-
time and archived weather and water data. States can use the Google Map feature to
locate stations within their waters. To view what type of data the station collects click on
the station marker. Majority of the stations collect pH data.

http ://cdmo. baruch. sc. ed u/QueryP ages/goo glemap. cfm

B.	NOAA National Data Buoy Center: Website contains data from all active NOAA and
other registered buoys. EPA recommends States use this website's Google Map feature
to locate buoys in their coastal waters and check for stations that monitor pH (also
includes NERRS stations).

http://www.ndbc.noaa.gov/

C.	Chesapeake Bay Interpretive Buoy System (CBIBS): Website contains weather and water
data from sampling stations in Chesapeake Bay. Gooses Reef Buoy records pH data.
http://www.buoybay.org/site/public/

2, Assessment Related to Ocean Acidification

EPA encourages coastal States to start developing assessment methods for evaluating marine
waters based on OA impacts using their existing marine pH and biological (narrative and
numeric) WQC. EPA reaffirms that States must list waters not meeting water quality standards,
including marine pH, based on existing and readily available water quality-related data and
information. Consistent with existing IR guidance, EPA also supports the use of predictive
modeling and other non-site-specific data such as remote sensing data, land use analysis, and
knowledge about pollutant sources and loadings, to make assessment decisions (2006 IR
Guidance, Section IV, part C [US EPA 2005]). Several coastal States specifically include a
provision in their IR for modeling to be used for listing purposes for all pollutants, although most
States do not include this as part of their assessment methodologies. Some States have listed
waters based on statewide advisories, or the presumption that the pollutant source (particularly
atmospheric deposition, such as mercury) is uniformly affecting segments in large geographic
areas. EPA supports the use of these methods for making attainment decisions related to OA
where appropriate.

Described below are several programs and articles that currently have useful information and
data on OA. EPA recommends States explore these sources to aid in developing strategies for
assessing OA impacts.

A. Ocean Carbon and Biogeochemistry (OCB) Program, http://www.whoi.edu/OCB-OA/:
This website provides a clearinghouse of OA news, information, and data resources to

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support the scientific research community. EPA recommends that States review these
websites and documents, especially the "Research Aids" section, to locate relevant
information and monitoring projects that can be used to support OA assessment.

Below are some key sections and documents found within OCB's website:

i.	"Ocean Acidification - Recommended Strategy for a U.S. National Research
Program" (OCB 2009a): The Whitepaper includes a list of additional sources,
reports and reviews on OA.

http://www.us-ocb.org/publications/OCB_0 A_Whitepaper.pdf

ii.	"Response to the EPA's call for Notice of Data Availability (NODA) on Ocean
Acidification and Marine pH Water Quality Criteria" (OCB 2009b):
http://www.whoi, edu/fileserver.do?id=62903&pt=2&p=73670

iii.	"Response to the EPA's call for public comment on ocean acidification and the
303(d) program" (OCB 2010):

http://www.whoi. edu/fileserver.do?id=62903&pt=2&p=73670

iv.	"Research Projects" section under "Research Aids": Includes list of programs and
projects that monitor ocean chemistry, explore OA effects on marine ecosystems,
and develop ocean chemistry models.
http://www.whoi.edu/OCB-OA/page.do7pid-32492

v.	"Data Tools and Resources" section under "Research Aids": Includes links to
ocean carbon data, coral reef data, time-series and moorings data from Ocean
Sites and the Carbon Dioxide Information Analysis Center (CDIAC), satellite
data, and ocean carbon modeling information.

http://www.whoi.edu/OCB-OA/page.do?pid=32493

B.	NOAA-Pacific Marine Environmental Laboratory (PMEL) Carbon Dioxide Program,
http://www.pmel.noaa.gov/co2/: Conducts ocean carbon cycle research from ships and
moorings in all of the major ocean basins in collaboration with the Atlantic
Oceanographic and Meteorological Laboratory (AOML) CO2 Program and the US
Climate Variability and Predictability (CLIVAR) CO2 Repeat Hydrography Program.
PMEL monitoring programs include:

i.	Air-Sea COi Exchange: Collects fugacity of carbon dioxide (fC02) in air and
seawater, sea surface temperature (SST), and salinity data

ii.	CO2 Time Series: Collects pC02 in air and seawater, and SST

iii.	Global Inventory Changes: Includes inorganic carbon measurements

C.	NOAA-PMEL Station Papa: Monitors ocean-atmosphere interactions, carbon uptake, and
OA. http://www.pmel.noaa.gov/smP/index.html

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D.	Integrated Ocean Observing System (IOOS):

Includes a data catalog where you can search by parameter, date, program, and data
providers. Note: Internet Explorer is slow to display the data catalog. Firefox, Safari,
and Chrome browsers work well, http://www.ioos.gov/

E.	Publications by Fabry et al. (2008), Feely et al. (2009), and Riebesell et al. (2010) identify
vulnerable ecosystems, measurement requirements, and other details for developing an OA
observational network (e.g., planned or deployed open-ocean and coastal OA monitoring
sites).

Natural Condition

As discussed previously, currently all 23 coastal States and five Territories have marine pH
WQC in place, and more than half of States' criteria contain a natural condition provision (e.g.,
"pH can range between 6.5 to 8.5, but not varying more than 0.2 units outside of the normally
occurring range.") However, most coastal States do not have detailed monitoring protocols,
assessment methods, or high-resolution equipment needed to quantify natural conditions within
their coastal waters, which is needed to implement such criteria. This absence is due to the fact
that marine pH concentrations can vary by depth, time of day, season, and location, making it
ditficult to monitor accurately. Additionally, historical pH datasets typically lack the necessary
detail needed for States to establish accurate baselines. While most States are not determining
natural condition for marine pH, a few States do address natural conditions in their assessment
methodologies (e.g., modeling can be used to determine natural background). In addition,
researchers are developing approaches to estimate historic marine pH values to draw conclusions
concerning OA impacts. For example, Feely et al, (2010) uses a C02SYS computer program
developed by Lewis and Wallace (1998) to estimate pre-industrial pH and current pH from
measured TA and DIC values. Therefore, to improve implementation of the marine pH criteria,
EPA suggests States begin requesting information on, and developing methods for, interpreting
their marine pH water quality standards related to natural condition.

Other 303(d)-Related Information

Consistent with EPA's 303(d) regulations and previous IR Guidance, EPA recommends that
States include in their IR methodology a description of how they consider available OA data and
information for assessment decisions, including statistical approaches and the QA/QC criteria
used to evaluate such data and information. Also, EPA reminds States that if a designated use is
not supported and the segment is impaired or threatened, the fact that the specific pollutant is not
known does not provide a basis for excluding the segment from being listed as impaired.
Therefore, if marine pH exceeds the State's criterion, but the source-stressor is unknown (e.g.,
carbon deposition, nutrient enrichment, industrial discharge, natural background), then EPA
expects the segment to be listed. In addition, to promote the identification of the pollutant(s)
causing the impairment, EPA recommends that States include other information that could
contribute to identifying the specific pollutant.

EPA also recommends that States consider using IR Category 3 for segments where there is
insufficient available data and/or information to make a determination related to OA. It is
possible that States have infonnation from other sources regarding OA impacts and could then
identify those segments that are higher and lower priority for foliow-up monitoring in the future,
using predicative tools such as probability surveys or landscape models. Category 3 provides

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States with the flexibility to monitor these segments in a manner consistent with their overall
monitoring strategy and schedule. (See page 5-6 of EPA's 2010 IR guidance [2009a] for more
detail on Category 3).

Separate IR section for Marine Water Seaments

EPA recommends that States consider including a separate assessment and listing section in their
IR report for information related to marine water segments (e.g., coastal waters, estuaries) and all
parameters separate from their freshwater segments, where practical. For example, Puerto Rico
in their 2010 Integrated Report has separate sections for their segmentation criteria and
assessment units of inland waters (rivers, streams, lakes, and estuaries) and coastal shoreline.
Location and size of segments are documented in separate tables. In addition, Puerto Rico
separates the listing of impaired waters into the following five tables: 1) rivers and streams, 2)
estuaries, 3) lagoons, 4) lakes, and 5) coastal shoreline. This separate marine/coastal section may
make it easier for States and the public to evaluate, review, and update methods and data related
to marine impairments, including OA.

3. Future Federal Efforts Related to Ocean Acidification

States are encouraged to track two key Federal efforts that should help them in developing
monitoring and assessment methods and protocols for use in developing future 303(d) lists.

First, on July 19, 2010, President Obama issued Executive Order (EO) 13547 that establishes the
Nation's first comprehensive National Ocean Policy for the stewardship of the ocean, our coasts,
and the Great Lakes (Obama 2010). The EO created an interagency National Ocean Council
(NOC) with the intent to strengthen ocean governance and provide sustained, high-level focus on
the national priority action objectives to advance the National Policy (available at
http://www.whitehouse.gov/administration/eop/oceans). The NOC is charged with developing
Strategy Action Plans for nine priority objectives, including "Climate Change Adaptation and
Ocean Acidification". Upon approval by the NOC, these 2011 action plans will guide Federal
government-wide implementation of ocean policy-related activities and budgets, including
development of a flexible framework for effective coastal and marine spatial monitoring and
planning.

Second, the FOARAM Act of 2009 directed the Joint Subcommittee on Science and Technology
(JSOST) to create an Interagency Working Group on Ocean Acidification (IWG-OA) to
coordinate OA activities across Federal agencies. This Interagency Committee, in which EPA
participates, is responsible for organizing and expanding research programs with the following
goals: to enhance understanding of the role of OA on marine ecosystems, identify marine
ecosystem conservation measures, facilitate information exchange on OA methods, and
investigate the socioeconomic impacts of OA. The IWG-OA is drafting a strategic research plan
for OA, to be completed in 2011. An initial report on the plan's progress, including a summary
of existing Federally-funded OA research and monitoring activities, including their budgets, was
recently completed (IWG-OA 2010).

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4. Biological Assessment, including Coral Reefs, Related to Ocean Acidification

EPA's current policy is that States should designate aquatic life uses for their waters that
appropriately address biological integrity and adopt biological criteria necessary to protect those
uses (US EPA 1991). To date, about half of the States now have narrative biological criteria and
a handful of States have numeric biological criteria in their water quality standards. Nearly one-
third of all States have written procedures describing how to use biological information to help
make aquatic life use attainment decisions (Russo 2009), but the majority of these measures and
methods apply to freshwater, not marine, systems. Species-specific assessments of biological
responses to chemical changes representative of OA have been performed (OCB 2009b), but the
NRC (2010) concluded that standardized, appropriate parameters for monitoring the biological
effects of OA generally cannot be determined until more is known concerning the physiological
responses and population consequences of OA across a wide range of taxa. However, where
more detailed information on specific aquatic resources (e.g., coral reefs, marine fisheries, or
shellfish resources) does exist, EPA encourages States to consider developing bioassessment
methods and/or biocriteria to reflect OA impacts.

EPA has detailed information on developing biocriteria and assessment methods at the following
website:

http://water.epa.gov/scitech/swguidance/waterquality/standards/criteri a/aqlife/biocriteria/biocrite
ria_index.cfm and within the documents, "Estuarine and Coastal Marine Waters: Bioassessment
and Biocriteria Technical Guidance" (US EPA 2000) and "Stony Coral Rapid Bioassessment
Protocol" (US EPA 2007). Additionally, States are referred to EPA's recent publication, "Coral
Reef Biological Criteria: Using the Clean Water Act to Protect a National Treasure" (US EPA
201 Od) for detailed information on different planning, assessment, and management steps
necessary for the development of coral reef biocriteria. Also, EPA's website for Biological
Indicators of Watershed Health includes more documents that States can use to assist in
developing bioassessments (http://www.epa.gov/bioiwebl/)

One data source that States can use to help them prioritize where to monitor and assess in the
future for OA impacts is EPA's National Coastal Condition Reports (NCCR)
(http://water.epa.gov/type/oceb/assessmonitor/nccr/index.cfm). These Reports assess the
Nation's coastal condition by evaluating five indicators of condition (water quality , sediment
quality, benthic community condition, coastal habitat loss, and fish tissue contaminants) in each
region of the U.S. (Northeast Coast, Southeast Coast, Gulf Coast, West Coast, Great Lakes,
Alaska, Hawaii, and Puerto Rico). Although these reports typically cannot be used to make site-
specific 303(d) listing decisions, they can be useful to States in identifying which coastal waters
have poor conditions, and therefore help States prioritize locations for future monitoring efforts
related to OA impacts. The most current NCCR Report was published in 2008 (US EPA 2008b)
and EPA is expecting to publish the next updated NCCR Report in late 2012.

Listed below are other resources that may be of use to States in their efforts to develop
bioassessments related to OA impacts:

A. Kleypas et al. (2006), "Impacts of Ocean Acidification on Coral Reefs and Other Marine
Calcifiers: A Guide for Future Research": This Workshop paper summarizes existing

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knowledge on OA impacts of marine calcifiers, presents a consensus on what the most
pressing scientific issues are, and identifies future research strategies for addressing these
issues. The report is intended to guide program managers and researchers toward
designing research projects with the details and references needed to address the major
scientific issues that should be pursued in the next 5-10 years.

B.	Fabry et al. (2008), "Present and Future Impacts of Ocean Acidification on Marine
Ecosystems and Biogeochemical Cycles": This Workshop report summarizes
information from nearly i 00 scientists and presents a comprehensive research strategy for
four critical ecosystems affected by OA: warm-water coral reefs, coastal margins,
subtropicai/tropical pelagic regions, and high latitude regions.

C.	Buddemeier et al. (2008), Coral Mortality and Bleaching Output (COMBO) Model 12:
Projects CO2 and high temperature bleaching event impacts to coral reefs. Developers
used coral reefs in Hawaii and US Virgin Islands to test importance of stressors and
priority areas for conservation.

D.	Bradley et al. (2009), "Development and Implementation of Coral Reef Biocriteria in
U.S. Jurisdictions": This article references different coral reef monitoring programs
within U.S. coastal waters.

E.	NOAA National Environmental Satellite, Data and Information Service (NESDIS)/ Coral
Reef Watch (CRW): Experimental Ocean Acidification Product Suite (OAPS) that
provides a synthesis of satellite and modeled environmental datasets to provide a synoptic
estimate of sea surface carbonate chemistry in the Greater Caribbean Region (includes
coastal waters along FL and PR). http://coraIreefwatch.noaa.gov/satellite/oa/index.html

5. Prioritization and TMDL Schedule Related to Ocean Acidification

States that iist coastal waters for marine pH and other OA-related impairments have the
discretion to prioritize their TMDL development schedule. CWA Section 303(d) and
implementing regulations at 40 C.F.R. §130.7 do not specify a timeframe for States to develop
TMDLs. However, EPA's current policy is that States can choose to rank the development of
TMDLs for listed waters in line with advancing technical and scientific methods, and generally
have between 8 to 13 years to develop TMDLs. Currently, EPA believes that not enough
information is available to develop OA-related carbon TMDLs, and is deferring development of
TMDL guidance related to OA listings until more information becomes available in the future.
States may want to take this information into account in setting the priority ranking for TMDL
development for any waters identified due to OA. However, States could address OA impacts
immediately by evaluating marine waters that are currently listed for other pollutants and that are
considered vulnerable to OA (e.g., waters with coral reefs, marine fisheries, shellfish resources).
For example, researchers have demonstrated that nutrient enrichment can also lead to decreases
in marine pH due to natural respiration processes and remineralizing dead organic matter back to
CO2 (Feely et al. 2010). States could focus their efforts on these OA-vulnerable waters to
promote ecological restoration.

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Federal Ocean Acidification Research and Monitoring (FOARAM) Act of 2009 (2009) Pub. L.
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