May 21, 2010 Clean Water Act Section 303(d): Notice of Call for Public Comment on 303(d) Program and Ocean Acidification Environmental Protection Agency 1200 Constitution Ave., NW, Mailcode: 4503–T Washington, DC 20460. Protecting our oceans from the threat of ocean acidification The world’s oceans are becoming more acidic from absorbing carbon dioxide emissions from the atmosphere to the tune of 22 million tons each day. Surface waters have become 30% more acidic since the industrial age, and scientists predict that if carbon dioxide emissions continue unabated seawater acidity will increase 100-150% by the end of the century (Nature 437:681-686). Thus, ocean acidification is becoming one of the greatest threats to seawater quality. Ocean acidification impairs the ability of marine animals — including corals, plankton, and shellfish — to build the protective shells they need to survive. Scientific evidence shows that ocean acidification may harm many marine organisms, and some of these impacts are already underway. Studies of certain corals, shellfish, and plankton show that they will have difficulty building and maintaining their structures under future conditions of acidification (Limnol. Oceanogr. 54(6):2072–2080, J. of Marine Sci. 65: 414–432, Geochem. Geophys. Geosyst. 10:Q07005). Slower growth rates have already been observed in some corals, and many corals could be lost within a few decades due to global warming and acidification (Science 323:116-119, Marine Pollution Bull. 58:1428-1436). Pacific Coast oyster hatcheries are experiencing difficulties that may be related to acidification, and two of the largest hatcheries report production rates down by as much as 80% (PLoS ONE 4(5):e5661). Some plankton are growing thinner and weaker shells in polar regions, which are more vulnerable to ocean acidification (Nature Geosci. 2:276-280). Studies show that exposure of fish, squid, and other animals to future levels of ocean acidification may disrupt metabolism and other biological functions (J. of Oceanogr. 60:705-718; PNAS 105:20776-20780; J. of Oceanogr. 60:731-741). Ocean acidification could have serious impacts on marine biodiversity, as well as the coastal communities and economies that depend on our oceans. The marine ecosystems threatened by ocean acidification provide valuable services ranging from fishing and shellfish harvesting to coastal tourism and protection. To prevent some of its worst consequences it is imperative that EPA take swift action to address ocean acidification. EPA leadership and guidance on ocean acidification is needed We support EPA implementing the Clean Water Act to address ocean acidification. The Clean Water Act’s objective is to restore and maintain the chemical, physical and biological integrity of the nation’s waters. It has successfully reduced water pollution and must be fully employed to address ocean acidification. Section 303(d) of the Clean Water Act is well suited to address ocean acidification because it was designed for water pollution problems originating from various sources, including the atmosphere. EPA should direct prompt action while such efforts can still avert the worst impacts of ocean acidification. Under the Clean Water Act, EPA can and should develop a framework coordinating state and federal action to prevent ocean acidification. Specifically, we urge EPA to: 1. Issue guidance on how to address ocean acidification under the Clean Water Act, including precautionary strategies for addressing this water quality problem. 2. Work with states to ensure the use of the best available science on ocean acidification when establishing water quality standards, identifying threatened and impaired waters, and calculating and implementing total maximum daily loads. 3. Provide guidance for state, tribal, and territorial governments on how to monitor ocean acidification and its ecological consequences; as well as promote management and adaptation planning for coastal and marine areas. EPA guidance would fulfill a critical need because as ocean acidification becomes more severe, all coastal regions will have to confront its impacts. Ocean acidification is already becoming apparent in vulnerable regions, including the entire West Coast, Alaska’s productive waters, and the Caribbean, which could soon threaten Florida’s coral reefs (Science 320:1490-92, Oceanogr. 22: 160-171, J. of Geophys. Res. 113:C10031). EPA guidance should inform strategic responses to ocean acidification. EPA action is needed to protect our coasts and oceans from the alarming impacts of ocean acidification. Moreover, approaches to ocean acidification under the Clean Water Act can and will complement local, state, and federal efforts to reduce carbon dioxide emissions. We thank you again for your leadership on environmental issues, and support EPA’s efforts to protect America’s oceans and coasts from ocean acidification. Most sincerely, David Guggenheim, PhD, President 1 Planet 1 Ocean Gillian Caldwell, Executive Director 1Sky May Boeve 350.org Toby Smith, Executive Director Alaska Center for the Environment Gus Rassam, PhD, Executive Director American Fisheries Society (AFS) David Helvarg, President Blue Frontier Campaign Carl Safina, PhD, President & Co-founder Blue Ocean Institute Sara Aminzadeh, Programs Manager California Coastkeeper Alliance Gershon Cohen Ph.D., Project Director Campaign to Safeguard American Waters Project of Earth Island Institute David Godfrey, Executive Director Caribbean Conservation Corporation Joe Payne Casco Baykeeper Miyoko Sakashita, Oceans Director Center for Biological Diversity Andrew J. Gunther, Ph.D., Executive Director Center for Ecosystem Management and Restoration Adrienne Esposito, Executive Director Citizens Campaign for the Environment Cindy Zipf, Executive Director Clean Ocean Action John DeCock, President Clean Water Action Mike Sandler, Co-Founder Climate Protection Campaign Christopher M. Kilian, Vice President Conservation Law Foundation. Brian Huse, Executive Director Coral Reef Alliance (CORAL) Mary Ann Lucking, Director CORALations Noah Matson, Vice President for Climate Change and Natural Resources Adaptation Defenders of Wildlife John Knox, Executive Director Earth Island Institute Margaret E. Sheehan, Partner EcoLaw Massachusetts Linda Krop, Chief Counsel Environmental Defense Center Scott Greacen, Executive Director EPIC – the Environmental Protection Information Center Bradley Angel, Executive Director Greenaction for Health and Environmental Justice Marcie Keever, Clean Vessels Campaign Director Friends of the Earth Kirsten Moller, Executive Director Global Exchange Damon Moglen, Global Warming Campaign Director Greenpeace USA Cyn Sarthou, Executive Director Gulf Restoration Network John W. Grandy, Ph.D., Senior Vice President Humane Society of the United States Pete Nichols Humboldt Baykeeper Andrew Kimbrell, Executive Director International Center for Technology Assessment David Phillips, Director International Marine Mammal Project of Earth Island Institute Payal Parekh, Climate Scientist International Rivers Marti Townsend, Program Director KAHEA: The Hawaiian-Environmental Alliance Lesley Adams, Rogue Riverkeeper Klamath-Siskiyou Wildlands Center Philip G. Renaud, Executive Director Living Oceans Foundation John Guinotte, Ph.D., Marine Biogeographer Marine Conservation Biology Institute John J. Clarke, Director of Public Policy & Government Relations Mass Audubon Bradford H. Sewell, Senior Attorney Natural Resources Defense Council (NRDC) Barbara Ettinger, Director Niijii Films, Inc. producers of A Sea Change: Imagine a World without Fish Tara Stetz Northcoast Environmental Center Jeff Short, Pacific Science Director Oceana Rob Moir, PhD, Executive Director Ocean River Institute David Gordon, Executive Director Pacific Environment Ed Tichenor, Director Palm Beach Reef Rescue Rebecca Tarbotton, Acting Executive Director Rainforest Action Network Paul G. Johnson, State Programs & Policy Director Reef Relief Dan Pingaro, CEO Sailors for the Sea Jill Witkowski San Diego Coastkeeper Jason Flanders San Francisco Baykeeper Kira Redmond, Executive Director Santa Barbara Channelkeeper Robert Wintner Snorkel Bob Foundation Leeona Klippstein, Executive Director Spirit of the Sage Council Kyle Gracey, Chair SustainUS Teri Shore, Program Director Turtle Island Restoration Network Kristine Stratton, Executive Director Waterkeeper Alliance Buffalo Bruce, Staff Ecologist Western Nebraska Resources Council Serge Dedina, Executive Director Wildcoast Kurt Beardslee, Executive Director Wild Fish Conservancy Scott Black Xerces Society for Invertebrate Conservation ___________________________________________________________________________________________________________________________ “Merging Our Deeper Currents” AFS 140st ANNUAL MEETING Pittsburgh, Pennsylvania 12-16 September 2010 http://secure.fisheries.org/afsevent Join AFS or renew for 2010 at www.fisheries.org/afs/membership.html