North American
Benthological Society
Mr. Benjamin Grumbles
Assistant Administrator, Office of Water
U.S. Environmental Protection Agency
Ariel Rios Building
Office of Water
1200 Pennsylvania Avenue, N.W.
Washington, DC 20460
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
Colorado State University
Fort Collins, CO 80523
970-491-2079
poff@lamar.colostate.edu
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 Update of 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, MD 20814-2199
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, MD 20814-2199
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, PA 16801
Society of Environmental Toxicology and Chemistry
Mr. Paul Goodson, Director
SETAC North America
1010 North 12th Avenue
Pensacola, FL 32501-3370
U.S. Geological Survey
Mr. P. Patrick Leahy, Acting Director
U.S. Geological Survey Headquarters
John W. Powell Federal Building
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