Document B5w6YOOEy1m9Xb4bExmgDZN8k

Science Advisory Board (SAB) Draft Report (2/27/17) for Quality Review - Do Not Cite or Quote. This draft has not been reviewed or approved by the chartered SAB and does not represent EPA policy. 1 2 3 EPA-SAB-17-xxx 4 5 The Honorable E. Scott Pruitt 6 Administrator 7 U.S. Environmental Protection Agency 8 1200 Pennsylvania Avenue, N.W. 9 Washington, D.C. 20460 10 11 Subject: SAB Review of Lake Erie Nutrient Load Reduction Models and Targets 12 13 Dear Administrator Pruitt: 14 15 The enclosed report provides the SAB's consensus advice and recommendations on the development of 16 nutrient-load reduction targets for Lake Erie. At the EPA's request, the SAB has reviewed the modeling 17 approach and results used to develop nutrient-load reduction targets for Lake Erie and provides advice 18 on an adaptive management approach to implementing nutrient reduction goals. 19 20 EPA Region 5 is co-leading a binational workgroup established under the Great Lakes Water Quality 21 Agreement to develop phosphorus load-reduction targets, strategies and action plans for Lake Erie. In 22 December 2014, the EPA received early advice from the SAB on a modeling approach to develop the 23 phosphorus-reduction targets. A binational workgroup of scientists (Modeling Subgroup) then used a 24 suite of models to generate a series of load-response curves to simulate the impact of phosphorus loads 25 on eutrophication indicators in Lake Erie. The load-response curves were used by the Great Lakes Water 26 Quality Agreement Annex 4 Objectives and Targets Task Team (Task Team) to identify phosphorus 27 reductions needed to meet indicator thresholds associated with desired ecological conditions. Two 28 documents were submitted to the SAB for review: (1) a report titled Annex 4 Ensemble Modeling Report 29 (May 2016 Peer Review Draft) and (2) a report titled Recommended Phosphorus Loading Targetsfor 30 Lake Erie, Annex 4 Objectives and Targets Task Team Final Report to the Nutrients Annex 31 Subcommittee (May 11, 2015). 32 33 The SAB was asked to respond to six charge questions that focused on: (1) the adequacy of the 34 evaluation of the models used to develop load-response curves; (2) whether the recommended 35 phosphorus load-reduction targets are based on the best available information; (3) whether scientifically 36 sound phosphorus load reductions can be developed to address growth of a nuisance alga, Cladophora-, 37 (4) whether nitrogen control, in addition to phosphorus, is warranted in Lake Erie; (5) recommended 38 approaches to assess progress in reducing loadings of phosphorus; and (6) recommendations for an 39 adaptive management approach to implement nutrient reduction goals for Lake Erie. 40 41 The SAB commends the EPA for its efforts to determine whether the models used to simulate and 42 evaluate the impact of phosphorus loads to Lake Erie meet standards that provide confidence in the 43 accuracy and reliability of results. The models used for the simulations are limited by the data available 44 for calibration and validation, and this affects the ability to rigorously evaluate model quality. The 45 Modeling Subgroup applied and evaluated the suite of models independently, rather than as part of an 46 ensemble approach; some models were accepted for use despite deficiencies relative to model evaluation 47 criteria. The SAB's major comments and recommendations are as follows: 17cv1906 Sierra Club v. EPA ED 001523 00003570-00001 Science Advisory Board (SAB) Draft Report (2/27/17) for Quality Review - Do Not Cite or Quote. This draft has not been reviewed or approved by the chartered SAB and does not represent EPA policy. 1 2 The models evaluated and used by the Modeling Subgroup are not of equal reliability. Assessment 3 of the response to phosphorus loads could be improved by giving greater weight to the load 4 response curves generated by the models deemed most reliable. Given the limitations of some of the 5 models evaluated, and the practical limits of funding, the number of models considered should be 6 reduced. It might prove most efficient to choose a single model and to further develop that model 7 using the insights and demonstrated capabilities provided by the other models and the results of 8 ongoing process research and monitoring. Consideration should be given to making Western Lake 9 Erie Ecosystem Model the consensus model for this purpose, with a goal of extending this model to 10 all of Lake Erie. 11 12 The SAB finds that the 40% reduction in total phosphorus load to the Western and Central Basins 13 of Lake Erie recommended by the Task Team will improve Lake Erie water quality and reduce 14 harmful algal blooms. However, even with this reduction, blooms may still occur with some 15 frequency, perhaps even routinely, in Maumee Bay in the Western Basin of Lake Erie. Ultimately, 16 greater load reductions may be necessary to achieve the desired thresholds in the eutrophication - 17 response indicators. Uncertainties in predictions of hypoxia are considerably larger than 18 uncertainties associated with predictions of algal blooms. Continued lake and tributary monitoring 19 and research will be needed to support adaptive management and the models used to simulate load 20 reductions. 21 22 Scientifically sound phosphorus load reduction recommendations to reduce Cladophora growth in 23 the Eastern Basin of Lake Erie cannot be developed at this time. The SAB finds that there is 24 insufficient information available to understand and weigh the relative importance of environmental 25 factors that might have causal links to Cladophora growth. The Great Lakes Cladophora Model can 26 be used to evaluate Cladophora occurrence and provide initial predictions of Cladophora biomass. 27 However, knowledge gaps must be filled before phosphorus load-reduction recommendations to 28 reduce Cladophora growth can be developed with an adequate level of certainty and scientific 29 confidence. 30 31 While phosphorus has always been considered the limiting nutrient for Lake Erie and most other 32 lakes, there is increasing evidence of the possible need for nitrogen control as well. In order to 33 evaluate the importance of nitrogen control in Lake Erie, research should be conducted to answer a 34 number of key questions and understand important relationships. These issues are identified and 35 discussed in the enclosed report. 36 37 Tracking flow-weighted mean concentrations of phosphorus in Lake Erie tributaries, as 38 recommended by the Task Team, is a useful approach for measuring progress in load reduction. 39 This approach accounts for variability in hydrology. However, the SAB recommends that all 40 available monitoring data (discharge, flow, concentrations and loads) from significant tributaries 41 and multiple assessment approaches be reviewed and used to evaluate efforts to reduce nutrient 42 loadings. The SAB also recommends that the uncertainty in values derived using flow-weighted or 43 flow-adjusted assessment approaches be explicitly quantified and presented, and that detailed 44 information on the implementation of phosphorus reduction strategies be collected to help identify 45 the reasons for observed changes in phosphorus loads delivered to Lake Erie. 46 17cv1906 Sierra Club v. EPA ED 001523 00003570-00002 Science Advisory Board (SAB) Draft Report (2/27/17) for Quality Review - Do Not Cite or Quote. This draft has not been reviewed or approved by the chartered SAB and does not represent EPA policy. 1 The SAB strongly endorses development of an adaptive management program to implement and 2 evaluate nutrient reduction goals for Lake Erie and recommends that the EPA formally appoint a 3 standing committee to develop and coordinate the program. The adaptive management program 4 should include long-term monitoring and application of process-based eutrophication models to 5 make annual predictions of eutrophication response indicators. The program should assess 6 empirical data against model results and test alternative hypotheses and conceptual models to help 7 explain discrepancies and use new knowledge to adjust management operations. The results of 8 these assessments and hypothesis and model testing will also guide future monitoring and modeling 9 efforts. In the enclosed report the SAB suggests a number of important research, monitoring, and 10 modeling tasks to provide information needed for nutrient-load reduction and management of 11 harmful algal blooms and hypoxia. 12 13 The SAB appreciates the opportunity to provide the EPA with advice on this important subject. We look 14 forward to receiving the agency's response. 15 16 17 Sincerely, 18 19 20 21 22 Enclosure 17cv1906 Sierra Club v. EPA ED 001523 00003570-00003 Science Advisory Board (SAB) Draft Report (2/27/17) for Quality Review - Do Not Cite or Quote. This draft has not been reviewed or approved by the chartered SAB and does not represent EPA policy. 1 NOTICE 2 3 This report has been written as part of the activities of the EPA Science Advisory Board (SAB), a public 4 advisory group providing extramural scientific information and advice to the Administrator and other 5 officials of the Environmental Protection Agency. The SAB is structured to provide balanced, expert 6 assessment of scientific matters related to problems facing the Agency. This report has not been 7 reviewed for approval by the Agency and, hence, the contents of this report do not necessarily represent 8 the views and policies of the Environmental Protection Agency, nor of other agencies in the Executive 9 Branch of the Federal government, nor does mention of trade names of commercial products constitute a 10 recommendation for use. Reports of the SAB are posted on the EPA Web site at 11 http://www.epa.gov/sab. 17cv1906 Sierra Club v. EPA ED 001523 00003570-00004 Science Advisory Board (SAB) Draft Report (2/27/17) for Quality Review - Do Not Cite or Quote. This draft has not been reviewed or approved by the chartered SAB and does not represent EPA policy. 1 2 U.S. Environmental Protection Agency 3 Science Advisory Board 4 Lake Erie Phosphorus Objectives Review Panel 5 6 7 CHAIR 8 Dr. William H. Schlesinger, President Emeritus, Cary Institute of Ecosystem Studies, Millbrook, NY 9 10 MEMBERS 11 Dr. Merryl Alber, Professor, Department of Marine Sciences, University of Georgia, Athens, GA 12 13 Dr. James Ammerman, Long Island Sound Study Science Coordinator, New England Interstate Water 14 Pollution Control Commission, Stamford, CT 15 16 Dr. Steven Bartell, Principal, Vice President, and Technical Director, Cardno ENTRIX, Greenback, TN 17 18 Dr. Hunter Carrick, Professor, Biology, Central Michigan University, Mount Pleasant, MI 19 20 Dr. Celia Chen, Research Professor, Department of Biological Sciences, Dartmouth College, Hanover, 21 NH 22 23 Dr. John P. Connolly, Principal, Anchor QEA, LLC, Woodcliff Lake, NJ 24 25 Dr. Richard Di Giulio, Professor, Nicholas School of the Environment, Duke University, Durham, NC 26 27 Dr. Robert Diaz, Professor Emeritus, Department of Biological Sciences, Virginia Institute of Marine 28 Science, College of William and Mary, Gloucester Pt., VA 29 30 Mr. Douglas Endicott, P.E., Great Lakes Environmental Center, Traverse City, MI 31 32 Mr. James J. Fitzpatrick, Project Principal Engineer, HDR Engineering, Mahwah, NJ 33 34 Dr. Robert T. Heath, Professor Emeritus, Department of Biological Sciences, Kent State University, 35 Kent, OH 36 37 Dr. Lucinda Johnson, Associate Director, Natural Resources Research Institute, University of 38 Minnesota Duluth, Duluth, MN 39 40 Dr. J. Vai Klump, Professor and Dean, School of Freshwater Sciences, Great Lakes Water Institute, 41 University of Wisconsin-Milwaukee, Milwaukee, WI 42 43 Dr. Thomas W. La Point, Professor Emeritus, Department of Biological Sciences, University of North 44 Texas, Denton, TX 45 46 ii 17cv1906 Sierra Club v. EPA ED 001523 00003570-00005 Science Advisory Board (SAB) Draft Report (2/27/17) for Quality Review - Do Not Cite or Quote. This draft has not been reviewed or approved by the chartered SAB and does not represent EPA policy. 1 Dr. Douglas McLaughlin, Principal Research Scientist, Northern Regional Center, National Council 2 for Air and Stream Improvement, Mattawan, MI 3 4 Dr. Ramesh Reddy, Graduate Research Professor, Soil and Water Science, University of Florida, 5 Gainesville, FL 6 7 Dr. Emma Rosi-Marshall, Senior Scientist, Cary Institute of Ecosystem Studies, Millbrook, NY 8 9 Dr. Eric P. Smith, Professor, Department of Statistics, Virginia Tech, Blacksburg, VA 10 11 Dr. William Stubblefield, Senior Research Professor, Department of Molecular and Environmental 12 Toxicology, Oregon State University, Corvallis, OR 13 14 Dr. Maurice Valett, Professor of Systems Ecology, Division of Biological Sciences, University of 15 Montana, Missoula, MT 16 17 18 SCIENCE ADVISORY BOARD STAFF 19 Dr. Thomas Armitage, Designated Federal Officer, U.S. Environmental Protection Agency, 20 Washington, DC 17cv1906 Sierra Club v. EPA ED 001523 00003570-00006 Science Advisory Board (SAB) Draft Report (2/27/17) for Quality Review - Do Not Cite or Quote. This draft has not been reviewed or approved by the chartered SAB and does not represent EPA policy. 1 U.S. Environmental Protection Agency 2 Science Advisory Board 3 4 5 CHAIR 6 Dr. Peter S. Thorne, Professor and Head, Department of Occupational & Environmental Health, 7 College of Public Health, University of Iowa, Iowa City, IA 8 9 10 MEMBERS 11 Dr. Joseph Arvai, Max McGraw Professor of Sustainable Enterprise and Director, Erb Institute, School 12 of Natural Resources & Environment, University of Michigan, Ann Arbor, MI 13 14 Dr. Deborah Hall Bennett, Professor and Interim Chief, Environmental and Occupational Health 15 Division, Department of Public Health Sciences, School of Medicine, University of California, Davis, 16 Davis, CA 17 18 Dr. Kiros T. Berhane, Professor, Preventive Medicine, Keck School of Medicine, University of 19 Southern California, Los Angeles, CA 20 21 Dr. Sylvie M. Bronder, Professor and Wickersham Chair of Excellence in Agricultural Research, 22 Department of Agronomy, Purdue University, West Lafayette, IN 23 24 Dr. Joel G. Burken, Curator's Professor and Chair, Civil, Architectural, and Environmental 25 Engineering, College of Engineering and Computing, Missouri University of Science and Technology, 26 Rolla, MO 27 28 Dr. Janice E. Chambers, William L. Giles Distinguished Professor and Director of the Center for 29 Environmental Health and Sciences, College of Veterinary Medicine, Mississippi State University, 30 Starksville, MS 31 32 Dr. Alison C. Cullen, Professor, Daniel J. Evans School of Public Policy and Governance, University 33 of Washington, Seattle, WA 34 35 Dr. Ana V. Diez Roux, Dean, School of Public Health, Drexel University, Philadelphia, PA 36 37 Dr. Otto C. Doering HI, Professor, Department of Agricultural Economics, Purdue University, W. 38 Lafayette, IN 39 40 Dr. Michael Dourson, Director, Toxicology Excellence for Risk Assessment Center, and Professor of 41 Environmental Health, College of Medicine, University of Cincinnati, Cincinnati, OH 42 43 Dr. Joel J. Ducoste, Professor, Department of Civil, Construction, and Environmental Engineering, 44 College of Engineering, North Carolina State University, Raleigh, NC 45 46 Dr. Susan P. Felter, Research Fellow, Global Product Stewardship, Procter & Gamble, Mason, OH 47 iv 17cv1906 Sierra Club v. EPA ED 001523 00003570-00007 Science Advisory Board (SAB) Draft Report (2/27/17) for Quality Review - Do Not Cite or Quote. This draft has not been reviewed or approved by the chartered SAB and does not represent EPA policy. 1 Dr. R. William Field, Professor, Department of Occupational and Environmental Health, and 2 Department of Epidemiology, College of Public Health, University of Iowa, Iowa City, IA 3 4 Dr. H. Christopher Frey, Glenn E. Futrell Distinguished University Professor, Department of Civil, 5 Construction and Environmental Engineering, College of Engineering, North Carolina State University, 6 Raleigh, NC 7 8 Dr. Joseph A. Gardella, SUNY Distinguished Professor and John and Frances Larkin Professor of 9 Chemistry, Department of Chemistry, College of Arts and Sciences, University at Buffalo, Buffalo, NY 10 11 Dr. Steven P. Hamburg, Chief Scientist, Environmental Defense Fund, Boston, MA 12 13 Dr. Cynthia M. Harris, Director and Professor, Institute of Public Health, Florida A&M University, 14 Tallahassee, FL 15 16 Dr. Robert J. Johnston, Director of the George Perkins Marsh Institute and Professor, Department of 17 Economics, Clark University, Worcester, MA 18 19 Dr. Kimberly L. Jones, Professor and Chair, Department of Civil and Environmental Engineering, 20 Howard University, Washington, DC 21 22 Dr. Catherine J. Karr, Associate Professor - Pediatrics and Environmental and Occupational Health 23 Sciences and Director - NW Pediatric Environmental Health Specialty Unit, University of Washington, 24 Seattle, WA 25 26 Dr. Madhu Khanna, ACES Distinguished Professor in Environmental Economics, Director of 27 Graduate Admissions, and Associate Director, Institute of Sustainability, Energy, and Environment, 28 Department of Agricultural and Consumer Economics, University of Illinois at Urbana-Champaign, 29 Urbana, IL 30 31 Dr. Francine Laden, Professor of Environmental Epidemiology, Harvard T.H. Chan School of Public 32 Health, Associate Professor of Medicine, Channing Division of Network Medicine, Brigham and 33 Women's Hospital and Harvard Medical School, Boston, MA 34 35 Dr. Robert E. Mace, Deputy Executive Administrator, Water Science & Conservation, Texas Water 36 Development Board, Austin, TX 37 38 Dr. Clyde F. Martin, Hom Professor of Mathematics, Emeritus, Department of Mathematics and 39 Statistics, Texas Tech University, Crofton, MD 40 41 Dr. Sue Marty, Senior Toxicology Leader, Toxicology & Environmental Research, The Dow Chemical 42 Company, Midland, MI 43 44 Dr. Denise Mauzerall, Professor, Woodrow Wilson School of Public and International Affairs, and 45 Department of Civil and Environmental Engineering, Princeton University, Princeton, NJ 46 47 v 17cv1906 Sierra Club v. EPA ED 001523 00003570-00008 Science Advisory Board (SAB) Draft Report (2/27/17) for Quality Review - Do Not Cite or Quote. This draft has not been reviewed or approved by the chartered SAB and does not represent EPA policy. 1 Dr. Kristina D. Mena, Associate Professor, Epidemiology, Human Genetics, and Environmental 2 Sciences, School of Public Health, University of Texas Health Science Center at Houston, El Paso, TX 3 4 Dr. Surabi Menon, Director of Research, ClimateWorks Foundation, San Francisco, CA 5 6 Dr. Kari Nadeau, Naddisy Family Foundation Professor of Medicine, Director, FARE Center of 7 Excellence at Stanford University, and Sean N. Parker Center for Allergy and Asthma Research at 8 Stanford University School of Medicine, Stanford, CA 9 10 Dr. James Opaluch, Professor and Chair, Department of Environmental and Natural Resource 11 Economics, College of the Environment and Life Sciences, University of Rhode Island, Kingston, RI 12 13 Dr. Thomas F. Parkerton, Senior Environmental Associate, Toxicology & Environmental Science 14 Division, ExxonMobil Biomedical Science, Houston, TX 15 16 Mr. Richard L. Poirot, Independent Consultant, Burlington, VT 17 18 Dr. Kenneth M. Portier, Vice President, Department of Statistics & Evaluation Center, American 19 Cancer Society, Atlanta, GA 20 21 Dr. Kenneth Ramos, Associate Vice President of Precision Health Sciences and Professor of Medicine, 22 Arizona Health Sciences Center, University of Arizona, Tucson, AZ 23 24 Dr. David B. Richardson, Associate Professor, Department of Epidemiology, School of Public Health, 25 University of North Carolina, Chapel Hill, NC 26 27 Dr. Tara L. Sabo-Attwood, Associate Professor and Chair, Department of Environmental and Global 28 Health, College of Public Health and Health Professionals, University of Florida, Gainesville, FL 29 30 Dr. William Schlesinger, President Emeritus, Cary Institute of Ecosystem Studies, Millbrook, NY 31 32 Dr. Gina Solomon, Deputy Secretary for Science and Health, Office of the Secretary, California 33 Environmental Protection Agency, Sacramento, CA 34 35 Dr. Daniel O. Stram, Professor, Department of Preventive Medicine, Division of Biostatistics, 36 University of Southern California, Los Angeles, CA 37 38 Dr. Jay Turner, Associate Professor and Vice Dean for Education, Department of Energy, 39 Environmental and Chemical Engineering, School of Engineering & Applied Science, Washington 40 University, St. Louis, MO 41 42 Dr. Edwin van Wijngaarden, Associate Professor, Department of Public Health Sciences, School of 43 Medicine and Dentistry, University of Rochester, Rochester, NY 44 45 Dr. Jeanne M. VanBriesen, Duquesne Light Company Professor of Civil and Environmental 46 Engineering, and Director, Center for Water Quality in Urban Environmental Systems (Water-QUEST), 47 Department of Civil and Environmental Engineering, Carnegie Mellon University, Pittsburgh, PA vi 17cv1906 Sierra Club v. EPA ED 001523 00003570-00009 Science Advisory Board (SAB) Draft Report (2/27/17) for Quality Review - Do Not Cite or Quote. This draft has not been reviewed or approved by the chartered SAB and does not represent EPA policy. 1 2 Dr. Elke Weber, Gerhard R. Andlinger Professor in Energy and the Environment, Professor of 3 Psychology and Public Affairs, Woodrow Wilson School of Public and International Affairs, Princeton 4 University, Princeton, NJ 5 6 Dr. Charles Werth, Professor and Bettie Margaret Smith Chair in Environmental Health Engineering, 7 Department of Civil, Architectural and Environmental Engineering, Cockrell School of Engineering, 8 University of Texas at Austin, Austin, TX 9 10 Dr. Peter J. Wilcoxen, Laura J. and L. Douglas Meredith Professor for Teaching Excellence, and 11 Director, Center for Environmental Policy and Administration, The Maxwell School, Syracuse 12 University, Syracuse, NY 13 14 Dr. Robyn S. Wilson, Associate Professor, School of Environment and Natural Resources, Ohio State 15 University, Columbus, OH 16 17 18 SCIENCE ADVISORY BOARD STAFF 19 Mr. Thomas Carpenter, Designated Federal Officer, U.S. Environmental Protection Agency, 20 Washington, DC 21 22 23 24 17cv1906 Sierra Club v. EPA ED 001523 00003570-00010 Science Advisory Board (SAB) Draft Report (2/27/17) for Quality Review - Do Not Cite or Quote. This draft has not been reviewed or approved by the chartered SAB and does not represent EPA policy. 1 Table of Contents 2 3 ACRONYMS AND ABBREVIATIONS......................................................................................................... ix 4 1. EXECUTIVE SUMMARY............................................................................................................................. 1 5 2. INTRODUCTION............................................................................................................................................. 6 6 3. RESPONSES TO EPA'S CHARGE QUESTIONS..................................................................................7 7 3.1. Approach for Developing Lake Erie Phosphorus Load Reduction Targets.................................... 7 8 3.1.1. Evaluation of the Models to Inform Interpretation of Results.....................................................7 9 3.1.2. Phosphorus Loading Targets...................................................................................................... 11 10 3.2. Cladophora Growth....................................................................................................................................17 11 3.2.1. Development of Recommendations to Address Nuisance Levels of Cladophora Growth...... 17 12 3.3. Nitrogen Control......................................................................................................................................... 20 13 3.3.1. Determining Whether Nitrogen Control is Warranted.............................................................. 20 14 3.4. Evaluation of Nutrient Reduction Targets............................................................................................24 15 3.4.1. Assessing Progress in Reducing Tributary Loadings of Phosphorus........................................ 24 16 3.4.2. Adaptive Management Program................................................................................................27 17 REFERENCES.....................................................................................................................................................33 18 APPENDIX A: THE EPA'SCHARGE QUESTIONS............................................................................... A4 19 20 21 22 23 24 25 26 27 28 29 30 31 32 viii 17cv1906 Sierra Club v. EPA ED_001523_00003570-00011 Science Advisory Board (SAB) Draft Report (2/27/17) for Quality Review - Do Not Cite or Quote. This draft has not been reviewed or approved by the chartered SAB and does not represent EPA policy. 1 2 3 4 nh4+ 5 ANAMMOX 6 BMP 7 CAEDYM 8 cm 9 DIN 10 DOC 11 DOP 12 DNRA 13 EcoLE 14 ELCOM 15 ELCM 16 ERI 17 FAC 18 FWMC 19 GLCM 20 GLWQA 21 HAB 22 MT 23 m 24 Pg 25 mg/L 26 N 27 NOT 28 NO3` 29 p 30 POC 31 ppb 32 P-Quota 33 SOD 34 SRP 35 TKN 36 TN 37 TP 38 TSS 39 USDA 40 WLEEM 41 WHO 42 Acronyms and Abbreviations Ammonium Anaerobic Ammonium Oxidation Best Management Practice Computational Aquatic Ecosystem Dynamics Model Centimeter Dissolved Inorganic Nitrogen Dissolved Organic Carbon Dissolved Organic Phosphorus Dissimilatory Nitrate Reduction to Ammonium Ecological Model of Lake Erie Estuary, Lake and Coastal Ocean Model Estuary and Lake Computer Model Eutrophication Response Indicator Flow Adjusted Concentration Flow Weighted Mean Concentration Great Lakes Cladophora Model Great Lakes Water Quality Agreement Harmfl Algal Bloom Metric Ton meter Microgram Milligrams Per Liter Nitrogen Nitrite Nitrate Phosphorus Particulate Organic Carbon Parts Per Billion Cellular Phosphorus Concentration Sediment Oxygen Demand Soluble Reactive Phosphorus Total Kjeldahl Nitrogen Total Nitrogen Total Phosphorus Total Suspended Solids U.S. Department of Agriculture Western Lake Erie Ecosystem Model World Health Organization 43 44 ix 17cv1906 Sierra Club v. EPA ED 001523 00003570-00012 Science Advisory Board (SAB) Draft Report (2/27/17) for Quality Review - Do Not Cite or Quote. This draft has not been reviewed or approved by the chartered SAB and does not represent EPA policy. 1 1. EXECUTIVE SUMMARY 2 3 EPA Region 5 is co-leading a binational workgroup to develop and implement the Nutrients Annex 4 ("Annex 4") of the 2012 Great Lakes Water Quality Agreement (GLWQA). Under Annex 4 the U.S. 5 and Canada committed to address eutrophication issues in Lake Erie by first establishing phosphorus (P) 6 objectives, loading targets and allocations for nearshore and offshore waters and subsequently 7 developing P-reduction strategies and domestic action plans. In December 2014, the EPA received early 8 advice from the SAB on a modeling approach to develop P-reduction targets. A binational workgroup of 9 scientists (The Annex 4 Objectives and Targets Task Team Modeling Subgroup) then used a suite of 10 models to generate a series of load-response curves to simulate the impact of P loads on cyanobacteria 11 biomass, hypoxia and nuisance Cladophora growth. These load-response curves were used by the Great 12 Lakes Water Quality Agreement Annex 4 Objectives and Targets Task Team (Task Team) to identify P 13 load reductions needed to produce desired ecological conditions for Lake Erie. 14 15 The EPA requested that the SAB review the modeling approach and results used to develop the P load 16 reduction targets for Lake Erie. The SAB was also asked to provide advice on how to periodically 17 evaluate the nutrient reduction targets. The EPA submitted two documents to the SAB for review: (1) a 18 report titled Annex 4 Ensemble Modeling Report (May 2016 Peer Review Draft) and (2) a report titled 19 Recommended Phosphorus Loading Targets for Lake Erie, Annex 4 Objectives and Targets Task Team 20 Final Report to the Nutrients Annex Subcommittee (May 11, 2015). The SAB was asked to respond to 21 six charge questions that focused on: (1) the adequacy of the evaluation of the models used to develop 22 load-response curves; (2) whether the recommended P load reduction targets are based on the best 23 available information on drivers of cyanobacteria growth and seasonal hypoxia in Lake Erie; (3) whether 24 scientifically-sound P load reductions can be developed to address the problem of Cladophora growth in 25 Lake Erie; (4) whether nitrogen (N) control, in addition to P, is warranted in Lake Erie to prevent 26 harmful algal blooms and manage hypoxia; (5) how to account for inter-annual variability in hydrology 27 when assessing progress in reducing loadings of P to Lake Erie; and (6) recommendations for an 28 adaptive management approach to implement nutrient reduction goals for Lake Erie. This executive 29 summary highlights the findings and recommendations of the SAB in response to the charge questions 30 provided in Appendix A. 31 32 Evaluation of the Models to Inform Interpretation of Results 33 34 The SAB was asked to comment on: (1) whether the evaluation of the models was adequate to inform 35 how model results should be interpreted, and (2) any additional analyses that may be needed to improve 36 future development and interpretation of the load-response curves for the eutrophication response 37 indicators. The Modeling Subgroup applied and evaluated the suite of models independently, rather than 38 as part of an ensemble approach; some models were accepted for use despite deficiencies relative to 39 model evaluation criteria. The SAB recognizes that the models are limited by the data available for 40 calibration and validation and this affects the ability to rigorously evaluate model quality. A better 41 understanding of the limitations of the data and the data requirements needed to produce higher certainty 42 in estimates should be sought. The model evaluations did not attempt to characterize the relative 43 strengths of each model or the consistency of descriptions of underlying key processes. Furthermore, all 44 of the load-response curves were treated as equally likely, despite differences in estimated load and 45 model uncertainty. The SAB finds that the models are not of equal reliability, and the assessment of 46 load-responses would have benefited by giving greater weight to response curves generated by the 1 17cv1906 Sierra Club v. EPA ED 001523 00003570-00013 Science Advisory Board (SAB) Draft Report (2/27/17) for Quality Review - Do Not Cite or Quote. This draft has not been reviewed or approved by the chartered SAB and does not represent EPA policy. 1 models that appear to be most reliable on the basis of the model evaluation. Although the model 2 evaluation included efforts to characterize uncertainty, the approaches used to quantify uncertainty 3 differed among the models. Therefore, assessed uncertainties cannot be compared across models and 4 uncertainties were not used to evaluate the likelihood that loading targets would achieve desired 5 threshold values of the selected ecosystem response. 6 7 The number of models considered for use should be reduced. Priority should be given to the process 8 based models that have the capability to account for the response to load reductions, climate changes 9 and relevant ecological processes such as the internal storage and recycling of nutrients. Given practical 10 limits of funding and the limitations of some of the models evaluated, consideration should be given to 11 further developing one process-based model using the insights and demonstrated capabilities provided 12 by the other models; the Western Lake Erie Ecosystem Model (WLEEM) could be the consensus model 13 for this purpose. 14 15 The SAB also recommends that synoptic sampling of key variables be conducted on an ongoing basis to 16 support continued model evaluation and refinement for Lake Erie. It is important to monitor flow, 17 nutrient concentration and total suspended solids in the significant tributaries to Lake Erie at sufficient 18 frequencies to make accurate estimates of loading. Estimates of loading could be further improved by 19 linking land-use models with loading models. If multiple models are used to derive load-response 20 information, consideration should be given to combining model estimates using either likelihood based 21 methods or Bayesian model averaging to produce a weighted quantitative characterization of the loading 22 curve and associated uncertainty. 23 24 Phosphorus Loading Targets 25 26 In order to meet ecosystem objectives1, the Great Lakes Water Quality Agreement Annex 4 Objectives 27 and Targets Task Team (Task Team) recommended a 40% reduction in the total P load to the Central 28 and Western Basins of Lake Erie. The SAB was asked to comment on whether the recommended 29 loading target reflects the best available information on the key drivers of cyanobacteria growth in the 30 Western Basin, and the potential link with seasonal hypoxia in the Central Basin. Based upon coupling 31 of the suite of models to the relatively long term observational record, the SAB finds a 40% reduction in 32 total P load will improve water quality and reduce the magnitude and extent of harmful algal blooms in 33 keeping with the stated goals in the Task Team report. In addition, the SAB recognizes that the focus of 34 abatement programs should be on reducing those nutrient components that readily support growth of 35 phytoplankton communities. This implies that a focus should be placed on reduction of soluble reactive 36 P (SRP), which is generally regarded as completely bioavailable, as well as those fractions of total P 37 (TP) that may be partially available to phytoplankton (e.g., certain particulate P and dissolved organic P 38 (DOP) fractions. However, even with this reduction, blooms may still occur with some frequency, 39 perhaps even routinely, in Maumee Bay in the Western Basin of Lake Erie. Ultimately, further load 40 reductions may be necessary to achieve the desired thresholds of the eutrophication response indicators. 41 Uncertainties in predictions of hypoxia are considerably larger than uncertainties associated with 42 predictions of algal blooms; the link between algal blooms and hypoxia in the Western Basin is not well 43 understood. A current weakness of the hypoxia evaluation is that multiple year runs of the process 1 The desired thresholds identified for eutrophication response indicators in Lake Erie were: (1) Western Basin cyanobacteria bloom biomass no less than that observed in 2004 or 2012, nine years out of ten, and/or reduced risk of nearshore localized blooms; and (2) Central Basin hypoxia August - September average hypolimnetic dissolved oxygen concentration of 2.0 mg/L or more (Great Lakes Water Quality Agreement Annex 4 Objectives and Targets Task Team 2015). 2 17cv1906 Sierra Club v. EPA ED 001523 00003570-00014 Science Advisory Board (SAB) Draft Report (2/27/17) for Quality Review - Do Not Cite or Quote. This draft has not been reviewed or approved by the chartered SAB and does not represent EPA policy. 1 models have not been conducted. Therefore, the development of a forwarded residual of P or organic 2 matter over time has not been simulated. 3 4 As previously indicated, continued lake and tributary monitoring will be needed to support further 5 development of the modeling and adaptive management programs. Additional information (e.g., 6 resuspension fluxes and sediment-water interactions, changes in the response of algal species to P over 7 time, N limitation information) will be needed in order to incorporate currently missing components in 8 the models. These components include: temporal variability in hydrodynamics; factors affecting P 9 uptake by algae; the role of N in mediating algal growth; controls of algal toxin production; internal P 10 loading; the role of dreissenid mussels; seasonality in the timing of nutrient loads; winter-spring diatom 11 blooms under ice; and the effects of climate change. 12 13 Development of Recommendations to Address Nuisance Levels of Cladophora Growth 14 15 The SAB was asked to comment on whether scientifically sound P-load reduction recommendations 16 could be developed to reduce nuisance Cladophora growth in the Eastern Basin of Lake Erie. 17 Cladophora is a green alga that grows attached to hard benthic substrates. The nuisance attribute of 18 Cladophora is that expansive growths of this alga can cover large nearshore regions leading to the 19 formation of "beach muck" and problems that arise from it. The SAB finds that recommendations to 20 reduce the P loadings to control Cladophora growth cannot be developed at this time. There is 21 insufficient information available to understand and weigh the relative importance of environmental 22 factors (including P inputs) that might cause Cladophora growth and senescence. There are limited 23 observations of the spatial extent of the Cladophora problem along the shore of the Eastern Basin of 24 Lake Erie. However, available information does point to a developing basin-wide problem of significant 25 magnitude that warrants immediate action. 26 27 The Great Lakes Cladophora Model (GLCM) provides a first-order evaluation of Cladophora 28 occurrence and initial predictions regarding the reduction of Cladophora biomass. However, knowledge 29 gaps must be filled before P-load reduction recommendations to control Cladophora growth can be 30 developed with an adequate level of certainty and scientific confidence. These knowledge gaps include 31 the needs to: calibrate the GLCM for use in the Eastern Basin of Lake Erie, understand the importance 32 of P loads from different tributaries and the effect of local hydrodynamics on Cladophora growth, 33 understand processes that lead to sloughing of Cladophora and its decay to "beach muck," and include 34 the GLCM in a broader whole lake model to forecast the likelihood of Cladophora growth. The GLCM 35 would be more useful if it could be further developed to understand the growth of other nuisance benthic 36 algae (e.g., Chara, Lyngbya, andSpirogyrd) that cause problems similar to those associated with 37 Cladophora. It is particularly important to link the data needs of the GLCM with the data collection 38 process. The EPA should evaluate what data are needed to reduce uncertainty in the model and better 39 predict algal growth and presence. 40 41 Determination of Whether Nitrogen Control is Warranted 42 43 The SAB was asked to provide recommendations to help determine whether consideration of N control, 44 in addition to P, is warranted to reduce eutrophication in Lake Erie. In particular, the SAB was asked to 45 identify questions, relationships, and research priorities related to N loading and cycling that must be 46 addressed. As further discussed in this report, there is increasing evidence that N control, as well as P 47 control, may be needed to reduce eutrophication in Lake Erie. The toxic cyanobacterium, Microcystis, 3 17cv1906 Sierra Club v. EPA ED 001523 00003570-00015 Science Advisory Board (SAB) Draft Report (2/27/17) for Quality Review - Do Not Cite or Quote. This draft has not been reviewed or approved by the chartered SAB and does not represent EPA policy. 1 the major concern in western Lake Erie, does not fix N and therefore requires a fixed N source. 2 Microcystis becomes more toxic when nitrate is abundant in lake water, but it can become N-limited in 3 western Lake Erie in late summer. Furthermore, the growth of nuisance benthic algae in the Lake is 4 fueled by loading of both N and P. 5 6 In order to evaluate the importance of N control in Lake Erie, future research should answer some key 7 questions and clarify important relationships. Key research questions include: (1) What are the total N 8 loadings entering Lake Erie over time and space (including all of the major species of N)? (2) What is 9 the N budget for Lake Erie? (3) How much external N loading can be removed by internal processes like 10 denitrification, ammonia volatilization and burial, and transformed by dissimilatory nitrate reduction to 11 ammonium (DNRA)?2 (4) What are the consequences of legacy N and P in the sediments and the 12 differences in internal P and N cycling? (5) What are the downstream consequences of not following a 13 dual nutrient strategy? (6) What is the importance of concentrations and ratios of N to other nutrients in 14 directing or controlling ecosystem functions? (7) What is the ratio of N to P that would be best for 15 ecosystem functioning? (8) How reliable are current models for assessing the role of N in Lake Erie 16 eutrophication and how can the models be improved to model the effects of N? In addition, the SAB 17 recommends that best management practices (BMPs) be developed or applied to achieve N reduction in 18 Lake Erie, and "lessons-leamed" case studies of nutrient reduction strategies for the Baltic Sea, Gulf of 19 Mexico, and other areas be applied to Lake Erie. Agricultural BMPs for P may help to control N but 20 may not be sufficient to attain the degree of N control that could be necessary. 21 22 Assessing Progress in Reducing Tributary Loadings of Phosphorus 23 24 The SAB was asked to comment on the use of flow-weighted mean concentrations (FWMC) and other 25 approaches that should be considered to account for inter-annual variability in hydrology when assessing 26 progress in reducing tributary loadings of P to Lake Erie. The FWMC is the preferred approach for 27 calculating average concentrations in tributaries with variable flows. To determine FWMC, the 28 concentration in each sample is weighted by both the accompanying time interval and the flow. The 29 Task Team has recommended using FWMCs of P in Lake Erie tributaries as a benchmark to track 30 progress in load reduction. A flow-weighted mean concentration normalizes loadings with respect to 31 flow so that year-to-year progress in nutrient control is not confounded by variability in inter-annual 32 hydrology. This is a useful approach but the SAB recommends that all available monitoring data 33 (discharge, flow, concentrations and loads) from significant tributaries and multiple assessment 34 approaches (including FWMC and flow adjusted concentrations) be reviewed and used to evaluate 35 controls on nutrient loadings. FWMC analysis alone may mask elevated concentrations of nutrients that 36 can result in algal blooms. Nutrient concentration (affected by nutrient loading) controls organism 37 responses, and the effect of temporal variability in nutrient concentration is an important consideration 38 in the management of harmful algal blooms, particularly for organisms that have rapid life cycles and a 39 rapid response to shifts in nutrient concentrations. The SAB notes that flow adjusted concentrations 40 (relating nutrient concentration to discharge flow) have been used to remove seasonality from tributary 41 monitoring data and more clearly identify annual trends. 42 43 The SAB recommends that the uncertainty in values derived using flow-weighted or flow-adjusted 44 assessment approaches be explicitly quantified and presented, and that detailed information on the 45 implementation of P reduction strategies be collected. Without this information, it will not be possible to 2 DNRA is dissimilatory nitrate reduction to ammonium, NO3- to NH4+. It is a transformation (not a removal) process 4 17cv1906 Sierra Club v. EPA ED 001523 00003570-00016 Science Advisory Board (SAB) Draft Report (2/27/17) for Quality Review - Do Not Cite or Quote. This draft has not been reviewed or approved by the chartered SAB and does not represent EPA policy. 1 identify the primary reasons for observed changes in P loads delivered to the Lake. If control of nutrients 2 other than P (e.g., N, silica, or other micronutrients) is considered, the SAB recommends that the same 3 assessment approaches be applied to tributary monitoring for those nutrients in order to evaluate efforts 4 to control sources of loadings. 5 6 Adaptive Management Program 7 8 The SAB was asked to comment on the key elements that should be included in an adaptive 9 management program to implement and evaluate nutrient reduction goals for Lake Erie. The SAB was 10 also asked to comment on the value of using existing eutrophication models to periodically evaluate P 11 loading targets and key response indicators. The SAB strongly endorses development of an adaptive 12 management program to implement and evaluate nutrient reduction goals for Lake Erie and recommends 13 that the EPA formally appoint a standing committee to develop and coordinate adaptive management. 14 The program should test alternative hypotheses and associated conceptual models that can be used to 15 adjust management operations and guide future monitoring and modeling. It is beyond the scope of this 16 report to develop a comprehensive list of alternative hypotheses for Lake Erie eutrophication. However, 17 the SAB suggests a number of research, monitoring and modeling tasks that focus on nutrient-load 18 reduction, control of cyanobacteria and Cladophora blooms and evaluating processes that influence 19 hypolimnetic dissolved oxygen. 20 21 The adaptive management program should include long-term monitoring to assess whether loading and 22 eutrophication response targets are being met. Long-term monitoring should involve: assessing P and N 23 loading information and developing standardized protocols for loading estimates; maintaining and 24 expanding current tributary monitoring; considering the potential for monitoring additional 25 eutrophication response indicators; and collecting appropriate data to calibrate and validate models. The 26 adaptive management committee should be tasked with evaluating alternative management strategies for 27 Lake Erie eutrophication and evaluating future scenarios. 28 29 The SAB recommends that process-based eutrophication models be used as part of the adaptive 30 management process (as previously indicated, consideration should be given to developing one process 31 based model). These models can be used to make annual predictions of eutrophication response 32 indicators and to test alternative hypotheses. The SAB recommends that: the models be refined based on 33 changing loadings and other new data; future scenarios be evaluated to understand the effects of climate 34 variability, estimates of uncertainty be improved in the models; lake models be linked to upstream 35 source functions through watershed modeling; and that cases where models do not perform well be used 36 to develop alternative hypotheses. 17cv1906 Sierra Club v. EPA ED 001523 00003570-00017 Science Advisory Board (SAB) Draft Report (2/27/17) for Quality Review - Do Not Cite or Quote. This draft has not been reviewed or approved by the chartered SAB and does not represent EPA policy. 1 2. INTRODUCTION 2 3 EPA Region 5 is co-leading a binational workgroup to develop and implement the Nutrients Annex 4 ("Annex 4") of the 2012 Great Lakes Water Quality Agreement (GLWQA). Under Annex 4 the U.S. 5 and Canada committed to address eutrophication issues in Lake Erie by first establishing phosphorus (P) 6 objectives, loading targets and allocations for nearshore and offshore waters and subsequently 7 developing P reduction strategies and domestic action plans. In December 2014, the EPA received early 8 advice from the SAB on a modeling approach to develop P reduction targets (U.S. EPA Science 9 Advisory Board 2015). A binational workgroup of scientists (The Annex 4 Objectives and Targets Task 10 Team Modeling Subgroup) then used a suite of models to generate a series of load-response curves to 11 simulate the impact of P loads on cyanobacteria biomass, hypoxia and Cladophora growth. An ensemble 12 modeling approach was considered for this analysis but the load-response curves were generated by 13 running the models individually. These load-response curves were used by the Great Lakes Water 14 Quality Agreement Annex 4 Objectives and Targets Task Team (Task Team) to identify P reductions 15 needed to meet indicator thresholds that reflected desired ecological conditions for Lake Erie. 16 The SAB provided early advice to the EPA on the proposed ensemble modeling approach for 17 developing P targets for Lake Erie (U.S. EPA Science Advisory Board 2015). The EPA then requested 18 that the SAB review the modeling results and process used to develop P load reduction targets for the 19 Lake. In addition, the EPA requested advice on an adaptive management approach to periodically 20 evaluate the nutrient reduction targets. The agency submitted two documents to the SAB for review: (1) 21 a report titled Annex 4 Ensemble Modeling Report (May 2016 Peer Review Draft), and (2) a report titled 22 Recommended Phosphorus Loading Targets for Lake Erie, Objectives and Targets Task Team Final 23 Report to the Nutrients Annex Subcommittee (May 11, 2015). 24 25 The SAB was asked to respond to six charge questions that focused on: (1) the adequacy of the 26 evaluation of the models used to develop load-response curves; (2) whether the recommended P load 27 reduction targets are based on the best available information on drivers of cyanobacteria growth and 28 seasonal hypoxia in Lake Erie; (3) whether scientifically-sound P load reductions can be developed to 29 address the problem of Cladophora growth in Lake Erie; (4) whether nitrogen (N) control, in addition 30 to P, is warranted in Lake Erie to prevent harmfol algal blooms and manage hypoxia; (5) approaches to 31 account for inter-annual variability in hydrology when assessing progress in reducing loadings of P to 32 Lake Erie; and (6) an adaptive management approach to implement nutrient reduction goals for Lake 33 Erie. In response to the EPA's request the SAB convened its Lake Erie Phosphorus Objectives Review 34 Panel to conduct the review. The Panel held a public meeting on June 21-22, 2016 and teleconference 35 meetings on October 12 and 13, 2016 to deliberate on responses to the charge questions and develop a 36 consensus report of its findings and recommendations. The Panel's draft report was reviewed and 37 discussed by the chartered SAB at a teleconference on insert date>>. This SAB report provides the 38 findings and recommendations of the SAB in response to the EPA charge questions (Appendix A). Key 39 recommendations are highlighted at the end of each section of the report. The key recommendations are 40 grouped to provide a relative indication of whether it may be most appropriate to implement them in the 41 short, intermediate, or long term. This listing is intended to offer suggestions that may be helpful to the 42 EPA in deciding how and when to allocate resources to support this work. 17cv1906 Sierra Club v. EPA ED 001523 00003570-00018 Science Advisory Board (SAB) Draft Report (2/27/17) for Quality Review - Do Not Cite or Quote. This draft has not been reviewed or approved by the chartered SAB and does not represent EPA policy. 1 3. RESPONSES TO EPA'S CHARGE QUESTIONS 2 3.1. Approach for Developing Lake Erie Phosphorus Load Reduction Targets 3 4 The Great Lakes Water Quality Agreement Annex 4 Objectives and Targets Task Team Modeling 5 Subgroup (Modeling Subgroup) evaluated nine models to predict the response of selected eutrophication 6 response indicators (ERIs) to different P load scenarios. Four response indicators were considered and 7 evaluated: (1) overall phytoplankton biomass, as represented by chlorophyll a; (2) cyanobacteria blooms 8 in the Western Basin; (3) hypoxia in the hypolimnion in the Central Basin; and (4) Cladophora in the 9 nearshore areas of the Eastern Basin. 10 11 The document, Ensemble Modeling Report (May 2016 Peer Review Draft) (Great Lakes Water Quality 12 Agreement Annex 4 Objectives and Targets Task Team Modeling Subgroup 2016) describes evaluation 13 of the models and development of load-response curves for the selected ecosystem response indicators 14 (ERIs) for Lake Erie. These load-response curves were used to develop P reduction targets to meet 15 thresholds of desired ecological conditions for Lake Erie (Great Lakes Water Quality Agreement Annex 16 4 Objectives and Targets Task Team 2015). The SAB was asked to comment on: whether the evaluation 17 of the models by the Modeling Subgroup was adequate to inform interpretation of model results; 18 whether additional analyses were needed to improve development and interpretation of load-response 19 curves; whether the recommended targets reflect the best information on the drivers of cyanobacteria 20 growth and seasonal hypoxia; and whether the recommended targets are appropriate to meet the nutrient 21 objectives defined in the Great Lakes Water Quality Agreement. 22 23 3.1.1. Evaluation of the Models to Inform Interpretation of Results 24 25 Charge Question 1. Please comment on whether the evaluation of the models was adequate to 26 inform how model results should be interpreted, given differences in model complexity and scale. 27 Please identify any additional analyses that may be needed to improve future development and 28 interpretation of the load-response curves for the eutrophication response indicators. 29 30 The SAB broke the response to this charge question into two sub-questions: 31 32 1 . Was the evaluation of the models adequate to inform how the model results should be 33 interpreted? 34 35 2 . What additional analyses may be needed to improve future development and interpretation of the 36 load-response curves? 37 38 Model Evaluations 39 40 The original approach for developing Lake Erie P load reduction targets, as described by the EPA in a 41 2014 consultation with the SAB (U.S. EPA Science Advisory Board 2015), was to estimate load 42 response curves from multiple models and combine these into a single model or ensemble estimate. 43 However, the models were applied and evaluated independently and were not used to develop an 44 ensemble estimate. The independent model evaluations were intended to ensure that the results of each 45 model met standards that would provide confidence that the model-generated load-response curves 7 17cv1906 Sierra Club v. EPA ED 001523 00003570-00019 Science Advisory Board (SAB) Draft Report (2/27/17) for Quality Review - Do Not Cite or Quote. This draft has not been reviewed or approved by the chartered SAB and does not represent EPA policy. 1 could be regarded as reasonably accurate and reliable. While adequate in concept, the criteria1 used for 2 the model evaluations were only loosely applied and models were accepted despite deficiencies relative 3 to the criteria. For example, the Estuary, Lake and Coastal Ocean Model (ELCOM) was accepted and 4 used to develop a load-response curve for Lake Erie Central Basin hypoxia despite having not been 5 calibrated to Central Basin dissolved oxygen. A sensitivity analysis was not performed for the ELCOM. 6 The Modeling Subgroup's use of a common set of metrics to evaluate model fit is admirable; however, 7 these metrics were not uniformly applied across the suite of models. In addition, if prediction is a goal of 8 management, the evaluation should have included a predictive measure of fit. The standard measures of 9 goodness of model fit are not predictive,2 and Modeling Subgroup assessments of the quality of the fit 10 may be optimistic for purposes of nutrient management. 11 12 The model evaluations had other limitations: these evaluations did not characterize the relative strengths 13 of each model or the consistency of descriptions of underlying key processes; and the suite of load 14 response curves were treated as equally likely, despite significant differences in estimated load and 15 uncertainty. The SAB finds that the assessed models are not of equal reliability and that the assessment 16 of load-responses would have benefited by giving greater weight to response curves generated by the 17 models deemed most reliable. 18 19 The overall model evaluation included efforts to characterize model uncertainty. The approaches used to 20 quantify model uncertainty differed among the models and, as a result, the assessed uncertainties cannot 21 be readily compared across models. Perhaps most importantly, the model uncertainties were not used to 22 evaluate the likelihood that the chosen loading targets would achieve the desired thresholds of 23 ecosystem response. While it is clear that meeting the loading targets would lead to improved values of 24 the selected ecosystem response indicators, other important outcomes are less clear. These include the 25 likelihood that the desired threshold levels would be achieved; how long it would take for improvements 26 to occur after the loading is reduced; and the effect of variations in hydro-meteorological forcing and 27 timing of loading on responses to load reduction. 28 29 Improving Future Development ofthe Load-Response Curves 30 31 Given the limitations of a number of the models used in the analysis and the practical limits of funding, 32 the SAB recommends reducing the number of models considered. Priority should be given to the 33 process-based models that can account for the response of key environmental processes to changes 34 driven by load reductions, climate changes and internal storage and recycling of nutrients. This 35 recommendation comes with the recognition that such models should have process descriptions 36 consistent with current technical ability to measure and model those processes. That is, the models 37 should not have process resolution that cannot be parameterized based on measurements. It might prove 38 most efficient to choose a single model and to further develop that model using the insights and 39 demonstrated capabilities provided by the other models and the results of ongoing process research and 1 The Task Team Modeling Subgroup applied the following criteria to evaluate the models: 1) ability to develop load response curves or provide other output for quantitative understanding of relevant questions; 2) applicability to objectives and metrics of interest; 3) extent and quality of calibration and confirmation; 4) extent of model documentation; and 5) level of uncertainty analysis available. 2 Goodness of fit is a measure of how well the model fits the data already used to estimate its parameters; predictive fit is a measure of the model's accuracy in predicting future data. 8 17cv1906 Sierra Club v. EPA ED 001523 00003570-00020 Science Advisory Board (SAB) Draft Report (2/27/17) for Quality Review - Do Not Cite or Quote. This draft has not been reviewed or approved by the chartered SAB and does not represent EPA policy. 1 monitoring. Consideration should be given to making Western Lake Erie Ecosystem Model (WLEEM) 2 the consensus model for this purpose, with a goal of extending this model to all of Lake Erie. 3 4 Analyses of the ability of the chosen model(s) to predict responses to changing conditions should be 5 conducted on an ongoing basis. Research and model development work should be funded to improve 6 model accuracy and reliability within the overall nutrient-loadings management and decision-making 7 framework. This continued model evaluation and refinement would facilitate making the model or 8 models useful operational tools as part of an ongoing adaptive management process. 9 10 The models are limited by the data available for calibration and validation, which affect the ability to 11 rigorously evaluate model quality. The EPA should seek a better understanding of the limitations of the 12 data and the data requirements needed to produce higher certainty in estimates. Additional in-lake 13 synoptic sampling of key variables such as vertically averaged cyanobacteria abundance, water column 14 and surface sediment nutrients (e.g., N and P), total suspended solids (TSS), and dreissenid mussel 15 biomass) should be conducted on an ongoing basis to support model evaluations and refinements. 16 17 Measurements of flow, TSS and nutrient concentrations in all the significant tributaries to Lake Erie 18 should be made at sufficient frequency each year to make accurate estimates of loading, particularly 19 during the March to July period. While there is adequate information available on historical loading 20 from major tributaries (e.g., the Detroit River and the Maumee River), there is inadequate information 21 available on small3 tributaries. It would be useful to develop a model of nutrient and TSS loading that 22 includes inputs from small tributaries. This would most likely be a hierarchical or Bayesian hierarchical 23 model that accounts for multiple factors. Additional monitoring might be required for adequate 24 estimation of model parameters and subsequent estimates of nutrient loadings from the small tributaries. 25 26 It seems worthwhile to improve the estimates of loading by linking land use models with loading models 27 to achieve a realistic picture of the landscape-level interactions that are likely to produce in-lake changes 28 (e.g., algal blooms, hypoxia, and Cladophora growth). Correspondingly, there might be an opportunity 29 to collaborate with farmers who are practicing precision agriculture in the Lake Erie watershed to better 30 estimate optimal fertilizer application rates as a way to reduce nutrient loading. The EPA should seek 31 opportunities to collaborate with the U.S. Department of Agriculture (USDA) to increase local farmers' 32 use of agricultural technologies aimed at more efficient use of fertilizers and reducing nutrient loadings 33 to Lake Erie. 34 35 If multiple models are retained for use in the analysis, model estimates should be combined using either 36 likelihood-based methods or Bayesian model averaging to produce a combined model-weighted 37 quantitative characterization of the loading curve and associated uncertainty. 38 39 3 For the time period 2011-2013, flows from the Detroit River contributed 94% of the flow into the Western Basin of Lake Erie and flows from the Maumee River contributed 4% of the flow into the Western Basin (Great Lakes Water Quality Agreement Annex 4 Objectives and Targets Task Team 2015). Small tributaries do not contribute significantly to the total discharge but they may have high concentrations of phosphorus. Maccoux et al. (2016) have estimated phosphorus loading for Lake Erie tributaries. 9 17cv1906 Sierra Club v. EPA ED 001523 00003570-00021 Science Advisory Board (SAB) Draft Report (2/27/17) for Quality Review - Do Not Cite or Quote. This draft has not been reviewed or approved by the chartered SAB and does not represent EPA policy. 1 Key Recommendations 2 3 Short Term: 4 5 Because the models used in the analysis are not of equal reliability, the SAB recommends that the 6 assessment of load-responses be improved by giving greater weight to response curves generated by 7 the models deemed most reliable. 8 9 Given the limitations of some models used in the analysis and the practical limits of funding, the 10 number of models considered should be reduced and priority should be given to the process-based 11 models that have the capability to account for the response of key processes. It might prove most 12 efficient to choose a single model and to further develop that model using the insights and 13 demonstrated capabilities provided by the other models and the results of ongoing process research 14 and monitoring. Consideration should be given to making the Western Lake Erie Ecosystem Model 15 (WLEEM) the consensus model for this purpose, with a goal of extending this model to all of Lake 16 Erie. 17 18 Research and model development work should be funded to improve model accuracy and reliability 19 within the overall nutrient loadings management and decision-making framework. 20 21 The EPA should investigate when and where data collection is needed to best inform the models and 22 reduce model and estimation uncertainty. Additional in-lake synoptic sampling of key variables such 23 as vertically averaged cyanobacteria abundance, water column and surface sediment nutrients (e.g., 24 N, P), TSS and dreissenid mussel biomass should be conducted on an ongoing basis to support 25 model evaluations and refinements. 26 27 Measurements of flow, TSS and nutrient concentrations in all the significant tributaries to Lake Erie 28 should be made at sufficient frequency each year to determine accurate estimates of loading, 29 particularly during the March to July period. 30 31 Estimates of loading should be improved by linking land use models with loading models. 32 33 Intermediate Term: 34 35 Analyses of the ability of the chosen model(s) to predict responses to changing conditions should be 36 conducted on an ongoing basis. 37 38 If multiple models are retained for use in the analysis, model estimates should be combined using 39 either likelihood based methods or Bayesian model averaging to produce a combined-model 40 weighted quantitative characterization of the loading curve and associated uncertainty. 41 42 Long Term: 43 44 A model of nutrient and TSS loading that includes inputs from small tributaries should be developed. 45 46 10 17cv1906 Sierra Club v. EPA ED 001523 00003570-00022 Science Advisory Board (SAB) Draft Report (2/27/17) for Quality Review - Do Not Cite or Quote. This draft has not been reviewed or approved by the chartered SAB and does not represent EPA policy. 1 3.1.2. Phosphorus Loading Targets 2 3 Charge Question 2. Please comment on whether the recommended targets reflect the best 4 available information on the drivers ofcyanobacteria growth and seasonal hypoxia in Lake Erie 5 and are appropriate to meet the nutrient Lake Ecosystem Objectives defined in the GLWQA (as 6 reflected in Table 1 on page 7 of the document titled Recommended Phosphorus Loading Targets 7 for Lake Erie). 8 9 The Annex 4 Objectives and Targets Task Team (Task Team) recommended a target of 40% reduction 10 in the total P (TP) load to the Central and Western Basins of Lake Erie (Great Lakes Water Quality 11 Agreement Annex 4 Objectives and Targets Task Team 2015). This is based upon the results from the 12 suite of models that compute load-response relationships between metrics of eutrophication response 13 indicators, namely harmfol algal blooms (HABs) and hypoxia, and loads leading to values for those 14 metrics. The principal issues considered by the SAB were: (1) whether this target of a 40% reduction 15 (from a 2008 baseline which is essentially equivalent to the current target load of 11,000 MT) is based 16 on and results from a rigorous analysis and modeling framework (reflecting the drivers of cyanobacterial 17 growth and seasonal hypoxia), and (2) whether such a reduction will meet the Lake Erie Ecosystem 18 objectives4. 19 20 In general, the SAB finds that, while the models used in the analysis vary in complexity and assessment 21 of uncertainty, and not all incorporate the same level of process dynamics, their congruence provides 22 sufficient confidence in the stated recommended target P load. A 40% reduction represents a major and 23 substantial decrease in P inputs, but is in keeping with reductions deemed necessary in other aquatic 24 environments suffering similar ecosystem impairments (e.g., Chesapeake Bay, Tampa Bay, and the Gulf 25 of Mexico); therefore, by comparison, the recommended magnitude of the load reduction target does not 26 seem unreasonable. However, it should also be recognized that the P load-response curves were 27 generated from models that have been developed over the past 40 years. There are compelling reasons to 28 believe that the lake ecosystem has changed since 1995 and these models may no longer provide reliable 29 responses to P load reductions. In general, the models disregard the potential role of "legacy P" in 30 sediments and the role of other elements (e.g., N and Si) in controlling blooms of phytoplankton 31 populations, which may compromise the rate and extent of ERI responses to external P load reductions. 32 33 Drivers ofCyanobacteria Growth and Seasonal Hypoxia 34 35 The principal driver for the models used in the analysis and their results is stimulation of primary 36 production by P loading which leads to excessive algal growth, harmful algal blooms and the production 37 of cyanobacterial toxins, principally microcystin - for which the World Health Organization (WHO) 38 drinking water limit is 1 part per billion (ppb) free plus cell bound (WHO 2003). Concentrations of 39 microcystin have exceeded 1,200 ppb in the Western Basin of Lake Erie. While the target load 40 reductions appear adequate to reduce cyanobacterial blooms, they do not ensure that toxin levels will be 41 reduced to levels that no longer pose health threats. The controls on toxin production are not well 42 understood and represent an important research need. 4 The desired thresholds identified for eutrophication response indicators in Lake Erie were: (1) Western Basin cyanobacteria bloom biomass no less than that observed in 2004 or 2012, nine years out of ten, and/or reduced risk of nearshore localized blooms; and (2) Central Basin hypoxia August-September average hypolimnetic dissolved oxygen concentration of 2.0 mg/L or more (Great Lakes Water Quality Agreement Annex 4 Objectives and Targets Task Team 2015). 11 17cv1906 Sierra Club v. EPA ED 001523 00003570-00023 Science Advisory Board (SAB) Draft Report (2/27/17) for Quality Review - Do Not Cite or Quote. This draft has not been reviewed or approved by the chartered SAB and does not represent EPA policy. 1 2 A secondary effect of excessive algal growth is the rapid deposition of algal-derived, labile detrital 3 organic matter that enhances consumption of dissolved oxygen leading to the formation of extensive 4 zones of hypoxic hypolimnetic waters in the Central Basin of the Lake during thermally stratified 5 summertime conditions. 6 7 The relationships developed between P loads and ERIs are inherently approximate, variable and 8 relatively uncertain. This is in part due to the relative simplicity of the models in attempting to reproduce 9 a very complex ecosystem having a very large degree of natural biological and hydrodynamic 10 variability. Clearly not all processes are modeled, and the process modeling is not always conducted at a 11 level of temporal and spatial resolution that would resolve all the active dynamics. As further discussed 12 below, some processes and dynamics are missing. However, the basic relationship between P loading 13 and algal production, though highly variable and likely influenced by other biogeochemical processes, is 14 deemed central and definitive for Lake Erie. Most telling in this regard is the simple observation of a 15 direct relationship between extent of cyanobacterial blooms and the spring P loading to the Western 16 Basin (see Stumpf et al. 2012; Great Lakes Water Quality Agreement Annex 4 Objectives and Targets 17 Task Team 2015). A notable example is the dramatic difference between the 2011 and 2012 blooms. 18 The 2011 bloom was the largest on record until 2015. In 2012, the spring P load was approximately one 19 sixth of the 2011 P load, and the corresponding 2012 bloom was only about 10% of the 2011 20 observation. The Lake Erie system clearly appears to respond to changes in P loading with a strong 21 correlation generally captured by the models. It must be recognized that other biogeochemical processes, 22 including N and silica cycling, are important. However, the SAB finds that setting P loading as the 23 initial driver in the Lake Erie system is appropriate and is consistent with the evidence. 24 25 The SAB recognizes that the focus of abatement programs should be on reducing those components that 26 readily support growth of phytoplankton communities. This implies that a focus should be placed on 27 reduction of soluble reactive P (SRP) that is generally regarded as completely available, as well as those 28 fractions of total P (TP) that may be partially available to phytoplankton (e.g., certain particulate P and 29 dissolved organic P [DOP] fractions). For example, in the Maumee River on average in 2002-2013 only 30 about 45% of the TP load was actually bioavailable, and although SRP makes up only 21% of the 31 average TP load, SRP makes up about 46% of the average bioavailable load.5 The mineralization of 32 organic phosphorus to orthophosphate is a pathway to bioavailability for part of the nonreactive 33 phosphorus component of total dissolved phosphorus. However, Baker et al. (2014a) found that in the 34 Maumee River at Waterville, Ohio, the conversion of dissolved organic phosphorus to orthophosphate 35 added little to the bioavailable P loads entering the Lake. Gradient driven desorption of orthophosphate 36 from particulate phosphorus provides a pathway to bioavailability for particulate phosphorus. However, 37 the portion of the particulate phosphorus that is chemically or physically bioavailable may not support 38 algal growth if that sediment is deposited or buried prior to orthophosphate release to the water column. 39 A study of storm water movement through the lower Maumee River and Maumee Bay showed 40 substantial deposition of sediment between the Waterville, Ohio sampling station and Maumee Bay 41 (Baker et al, 2014b). These observations of sediment deposition underscore the relative importance of 42 SRP loading as a driver of cyanobacterial blooms. Moreover, a recent study indicates that changes in 43 agricultural practices, including some conservation practices designed to reduce erosion and particulate 5 Comments to the Science Advisory Board from Dr. David. Baker, October 24. 2016, available at: https://yosemite. epa.gov/sab/sabproduct.nsf/ AF08F14F2631437D85258057007053C8/$File/Comments+from+David+Baker, +Heidelberg+University.pdf 12 17cv1906 Sierra Club v. EPA ED 001523 00003570-00024 Science Advisory Board (SAB) Draft Report (2/27/17) for Quality Review - Do Not Cite or Quote. This draft has not been reviewed or approved by the chartered SAB and does not represent EPA policy. 1 P transport, may have had unintended, cumulative, and converging impacts contributing to increased 2 SRP loads to Lake Erie during the past 20 years (Jarvie et al. 2017). 3 4 The SAB notes that some of the process models do include other nutrients (N and silica) and other algal 5 speciation and as such do not totally rely on P loading to drive the system. In fact, nitrate concentrations 6 in the Maumee River have actually been decreasing and the relationship between P and N is not one of 7 simple stoichiometry. As discussed in Section 3.3.1 of this report, taking a dual nutrient management 8 approach in Lake Erie clearly warrants investigation, and is currently limited by a lack of data, primarily 9 on N cycling. The algal community in Lake Erie should be characterized to better understand the 10 relative contribution of N-fixers versus non-fixers. The role of both N-fixation and denitrification in N 11 cycling and N budgets in the system should also be assessed. This will provide information about the 12 importance of N limitation and the potential impact of N reduction strategies (i.e., if N is low, it might 13 stimulate N-fixing species). 14 15 The forms of P coming off the landscape are also critical to changes within the Lake Erie system. While 16 TP load has not changed significantly (i.e., there has been no long term trend up or down, even though 17 year to year variation has been high), the fraction of this TP that is "bioavailable" has increased 18 significantly in the last 20 years. This appears to be one of the drivers of cyanobacterial growth, 19 although it should be noted that "turning off' SRP in the models does not reduce cyanobacteria growth 20 enough to reach the maximum allowable cyanobacterial mass in established objectives (i.e., particulate P 21 also plays a role in cyanobacterial growth). 22 23 The timing of nutrient inputs is also important to cyanobacterial blooms. It would be useful to evaluate 24 whether there has been an increase in frequency and magnitude of blooms in response to nutrient inputs 25 over time and to recognize how the critical spring period may change or shift in the future. 26 27 Uncertainties in predictions of hypoxia are considerably larger than uncertainties associated with 28 predictions of algal blooms. This is due to the fact that the extent and dynamics of hypoxia are 29 confounded by many factors including physical processes, as well as biological processes such as the 30 extent of the winter bloom. Furthermore, whereas the connection between P loads and algal production 31 is relatively direct, the connection between P loading and Central Basin hypoxia is not. Hypoxia is 32 propagated through several functions from P loading to algal production, to rapid deposition of algal 33 detritus, to benthic metabolism and respiration, to oxygen depletion and hypoxia and the potential flux 34 of SRP and dissolved inorganic N (DIN) from the sediment bed during hypoxic events. These functions, 35 in turn, are heavily modified by thermal stratification driven by both short term physical mixing and 36 long term regional climate change. Hence, the lack of a direct relationship between P loading and 37 hypoxia is to be expected, since (in the words of Professor Clifford Mortimer of the Center for Great 38 Lakes Studies at the University of Wisconsin-Milwaukee) "many other spoons stir the pot." These 39 processes may influence whether hypoxia targets (see footnote 3 of this report) are achievable, and 40 certainly impact the ability of the models to capture the dynamics of hypoxia and predict a robust 41 relationship between P loading and oxygen depletion in the Central Basin. Better parameterization of 42 benthic metabolism and sediment oxygen demand is necessary as well, through inclusion of explicit sub 43 models of sediment diagenesis. 44 45 One current weakness of the evaluation of the hypoxia simulation models derives from the fact that 46 these process models, which can be run for multiple years, have only been run as one year simulations 47 using the same initial boundary or starting conditions in each case. This means that the development or 13 17cv1906 Sierra Club v. EPA ED 001523 00003570-00025 Science Advisory Board (SAB) Draft Report (2/27/17) for Quality Review - Do Not Cite or Quote. This draft has not been reviewed or approved by the chartered SAB and does not represent EPA policy. 1 accumulation of a forwarded residual of "legacy" P or organic matter over time is not currently 2 simulated. This accumulating residual, which would affect the response time of the system to a 3 reduction in loading, is present in both the Western and Central Basins of Lake Erie (Carrick et al. 4 2005). This response time is probably related to the residence time of metabolizable material and the 5 build-up of reduced chemical species in the sediments that may prolong hypoxia. In some systems this 6 has resulted in a lag in response to loading reductions on the order of years (Jeppesen et al. 2005; 7 Matzinger et al. 2010). 8 9 The rationale for an August-September hypolimnetic oxygen tolerance of 2 mg/L, as opposed to a more 10 stringent 4 mg/L which would require a greater P load reduction, is described in the document 11 Recommended Phosphorus Loading Targets for Lake Erie (Great Lakes Water Quality Agreement 12 Annex 4 Objectives and Targets Task Team 2015). Given the uncertainties in the hypoxia simulations, 13 the SAB finds that 2 mg/L is a reasonable initial target. It should be noted, however, that even with a 14 40% reduction in P loading, the dissolved oxygen water quality standard of 5 mg/L will, almost 15 certainly, not be met in Central Basin bottom waters and the predicted hypoxic area will range from 16 approximately 2,000 to nearly 6,000 km2 for periods in excess of a month. The WLEEM is a process 17 based model that can provide information on the relationship between loadings of water, sediments, and 18 nutrients and the responses of algal biomass and turbidity/sedimentation. The SAB recommends that the 19 WLEEM be deployed for the whole lake in order to provide information to better understand how load 20 reductions impact hypoxia development. 21 22 Missing Components ofthe Models 23 24 The Modeling Subgroup acknowledged that some of the simulation models used to develop load 25 response curves had missing components (Great Lakes Water Quality Agreement Annex 4 Objectives 26 and Targets Task Team Modeling Subgroup 2016). Undoubtedly missing components reflect a variety 27 of processes that are absent or minimally incorporated into the models, although some models are 28 capable of including these processes in future renditions. Such missing components include: 29 30 Temporal variability in the underlying hydrodynamics (e.g., strength and propagation of the Detroit 31 River plume in controlling the water residence time and flushing of the western basin); 32 Variations and the vagaries of weather for which the models have no simple means of inclusion; 33 The role of N limitation, denitrification and N fixation; 34 The controls of algal toxin production (not all Microcystis produces toxin, and there is some 35 indication that N may play a role); 36 The internal P loading and resuspension and sediment-water interactions in general - although the 37 WLEEM does include a diagenetic sub-model based on a 10-cm thick sediment mixed layer (The 38 SAB finds that a 10-cm thick sediment mixed layer may be too deep; approximately 5 cm would 39 seem to be more appropriate and in agreement with radionuclide chronologies) (Klump et al. 40 unpublished data 20066; Robbins et al. 1977). 41 Role of dreissenid mussels, the populations of which are likely not in steady state; 42 Changes in seasonality (e.g., the timing and the biogeochemical composition of P in load delivery 43 and how that is tied to activities in the watershed such as fertilizer application and tillage; 6 Klump, J.V. Great Lakes Water Institute, University of Wisconsin-Milwaukee, Milwaukee, WI. 14 17cv1906 Sierra Club v. EPA ED 001523 00003570-00026 Science Advisory Board (SAB) Draft Report (2/27/17) for Quality Review - Do Not Cite or Quote. This draft has not been reviewed or approved by the chartered SAB and does not represent EPA policy. 1 Changes in the P-uptake response of cyanobacteria and other algal species to TP and other forms of 2 P (e.g., bioavailable forms) over time (there is clear evidence that the system continues to shift and 3 that recent blooms are fundamentally different from those experienced in the 1970s); and 4 Incorporation of winter-spring diatom blooms under the ice. 5 6 All of these issues were discussed to varying degrees by the experts who attended the SAB Lake Erie 7 Phosphorus Objectives Review Panel meeting on June 21-22, 2016. Model predictions could be 8 improved by undertaking work to incorporate these missing components. In particular, the SAB notes 9 the importance of extending mechanistic models to include sediment diagenesis and nutrient flux (and 10 refine the depths of the active layer) and incorporating the influence of winter blooms into the models. 11 Consideration should also be given to embedding a Cladophora model within the whole lake WLEEM 12 (the SAB's findings and recommendations concerning Cladophora growth are discussed in the response 13 to Charge Question 3). 14 15 Importance ofClimate Change 16 17 It has also been well recognized that, because of climate change, management practices put in place 18 today may not result in the same ecosystem outcomes in the future (Great Lakes Water Quality 19 Agreement Annex 4 Objectives and Targets Task Team 2015; Great Lakes Water Quality Agreement 20 Annex 4 Objectives and Targets Task Team Modeling Subgroup 2016). The Task Team has indicated 21 that achieving flow weighted mean concentration (FWMC) objectives for TP and SRP is expected to 22 result in P loads below targets 90% of the time (i.e., 9 out of 10 years) "if precipitation patterns do not 23 change" (Great Lakes Water Quality Agreement Annex 4 Objectives and Targets Task Team 2015). The 24 Lake Erie region is projected to be both warmer and wetter in the future. As outlined by Bosch et al. 25 (2014), projections of climate change scenarios include: 26 27 Increased precipitation (-10-20%); 28 Increases in the frequency of intense precipitation events (important in a system that is event driven, 29 where perhaps 70% or more of the loading from the watershed occurs over 10-15 days of the year, 30 and where high precipitation after fertilizer application is likely to be important); 31 Expanded summertime conditions and a longer growing season; 32 Prolonged thermal stratification and hypolimnetic sequestration; 33 Changes in regional climatology and wind fields; 34 Changing lake levels, which in Lake Erie have the potential to significantly change the thickness of 35 the hypolimnion and its oxygen carrying capacity; 36 Changes in ice cover - including extent, duration and timing; and 37 Watershed changes (e.g., increases in crop production due to variables such as increased 38 precipitation and atmospheric CO2; increases in evapotranspiration rates, which in some systems 39 actually is projected to decrease runoff; and changes in soil microbial activity). 40 41 The SAB notes that some of the models used by the Task Team to predict the response of selected 42 eutrophication response indicators to P loading (e.g., WLEEM) are capable of incorporating elements of 43 climate change scenarios. 44 45 46 15 17cv1906 Sierra Club v. EPA ED 001523 00003570-00027 Science Advisory Board (SAB) Draft Report (2/27/17) for Quality Review - Do Not Cite or Quote. This draft has not been reviewed or approved by the chartered SAB and does not represent EPA policy. 1 Effects ofPhosphorus Load Reductions on Fish Production 2 3 Experts who attended the SAB Lake Erie Phosphorus Objectives Review Panel meeting on June 21-22, 4 2016 noted the concern of some resource managers that P load reductions could have a detrimental 5 effect on fish production. To the contrary, reductions in P loading could shift algal speciation in favor of 6 more species that are more palatable to primary consumers and may in fact enhance the food web by 7 restoring a trophic pathway to secondary and tertiary production (Yurk and Ney 1989; Ludsin et al. 8 2001). Cyanobacteria have long been considered a poor quality food for key zooplankton grazers that 9 link phytoplankton to higher trophic levels (Ali Ger et al. 2016). Therefore, at present, much of the 10 primary production (cyanobacteria) in Lake Erie probably represents an ecological dead end (i.e., it does 11 not enter the food chain but simply sinks to the bottom). Alterations in fish habitat and the abundance of 12 mussels also have an effect on fish abundance but this effect is not well understood. 13 14 Appropriateness ofthe Phosphorus Load Targets 15 16 In general, the SAB finds that, based upon the coupling of current models to a relatively long term 17 observational record, a 40% reduction in TP load to the Western and Central Basins projects an 18 estimated response which improves water quality and reduces HABs in keeping with the stated goals in 19 the Task Team report (Great Lakes Water Quality Agreement Annex 4 Objectives and Targets Task 20 Team 2015). However, even with this reduction, cyanobacteria blooms may still occur with some 21 frequency in the western arm of the western basin in Maumee Bay. Ultimately, greater load reductions 22 may be necessary to achieve the desired thresholds for the ERI's. As previously noted, prediction of 23 hypoxia is associated with a higher degree of uncertainty than prediction of cyanobacteria blooms. 24 Therefore, attenuation of hypoxia is more problematic. 25 26 As previously mentioned, lake and tributary monitoring is critical for continued development of the 27 models and for adaptive management. Lags in indicator response and inter-annual trends can only be 28 elucidated accurately with an adequate monitoring program in place. In particular, monitoring of the 12 29 priority watersheds identified by the Annex 4 Objectives and Targets Task Team is essential and should 30 include measurement of: precipitation, flow, N species (good in situ NOa' sensors are available for high 31 temporal resolution sampling), P (all forms) and organic carbon (dissolved organic carbon [DOC] and 32 particulate forms). Event based sampling (to capture the effects of the rising and falling limb) within 33 these systems is also critical for calculating loads. 34 35 The SAB also finds that linking the in-lake models to models of nutrient loading in the watershed is 36 essential, and is underway in some regions. The inclusion of these landscape models in the analysis is an 37 inescapable necessity since actions and practices on the land will enable the 40% P load reduction to the 38 Western and Central Basins. 39 40 Key Recommendations 41 42 Short Term: 43 44 Lake and tributary monitoring should be conducted to support continued development of the models 45 and adaptive management. In particular, event based sampling to capture the effects of precipitation 46 and tributary flow is critical for calculating loads. Dissolved organic or non-reactive P in Lake Erie 47 and tributaries should also be further investigated. 16 17cv1906 Sierra Club v. EPA ED 001523 00003570-00028 Science Advisory Board (SAB) Draft Report (2/27/17) for Quality Review - Do Not Cite or Quote. This draft has not been reviewed or approved by the chartered SAB and does not represent EPA policy. 1 2 Mechanistic models should be extended to include sediment diagenesis and nutrient flux. The depths 3 of the active layer should be refined (e.g., 10 cm is too large - the depth may be 5 cm or less). This 4 will require calibration of the mechanistic models to field and laboratory data specific to Lake Erie. 5 6 If feasible, given the computational resources that may be required, simulations should be run 7 continuously over a period of years as an extended sequence rather than resetting initial conditions 8 every year. 9 10 Intermediate Term: 11 12 If feasible, given the computational resources that may be required, the WLEEM should be deployed 13 for the whole lake to provide information to better understand how load reductions impact hypoxia 14 development. 15 16 Consideration should be given to embedding a Cladophora model within the whole lake WLEEM. 17 18 A better understanding of the influence of winter blooms (under ice phenomena) should be 19 developed and incorporated into the models, particularly for hypoxia in the Central Basin. 20 21 The algal community should be characterized to better understand the relative contribution of N- 22 fixers versus non-fixers. The role of both N-fixation and denitrification in N cycling and N budgets 23 in the system should be assessed. 24 25 3.2. Cladophora Growth 26 27 In its charge to the SAB, the EPA has indicated that additional P load reductions may be necessary to 28 reduce nuisance levels of Cladophora in the nearshore waters of the Eastern Basin of Lake Erie. The 29 SAB was asked to comment on whether scientifically sound P load reduction recommendations could be 30 developed at this time to address Cladophora growth. In responding to this charge question, the SAB 31 considered available information about Cladophora ecology, its occurrence in Lake Erie, the ecosystem 32 consequences of Cladophora blooms and capabilities of the Great Lakes Cladophora Model. 33 34 3.2.1. Development of Recommendations to Address Nuisance Levels of Cladophora Growth 35 36 Charge Question 3. Can scientifically-soundphosphorus load reduction recommendations be 37 developed at this time that will reduce Cladophora growth in the Eastern Basin ofLake Erie? 38 39 The SAB finds that further research must be completed before scientifically sound P load reduction 40 recommendations to reduce Cladophora growth in the Eastern Basin of Lake Erie can be developed. 41 There is insufficient information available to understand and weigh the relative importance of 42 environmental factors (including P inputs) that might have causal links to Cladophora growth and 43 senescence. Moreover, there are limited observations of the spatial extent of a perceived Cladophora 44 problem that seems to have been identified at sites along the shores of the Eastern Basin of Lake Erie. 45 That said, the issue of nuisance Cladophora growth in nearshore regions has been identified as an 46 important issue in the Great Lakes because it affects selected sites in each of the Great Lakes (Auer et al. 47 2010). This makes it a pressing regional issue in need of scientific and management attention. 17 17cv1906 Sierra Club v. EPA ED 001523 00003570-00029 Science Advisory Board (SAB) Draft Report (2/27/17) for Quality Review - Do Not Cite or Quote. This draft has not been reviewed or approved by the chartered SAB and does not represent EPA policy. 1 2 Basic Ecology ofCladophora 3 4 Cladophora glomerata is a macroscopic, filamentous, branched green alga (Chlorophyceae) that usually 5 grows attached to hard benthic substrates in a variety of lakes, streams and rivers worldwide (Wehr et al. 6 2015). This alga can grow in such profusion that it forms extensive, dense mats achieving several meters 7 in length. The occurrence of this alga is usually associated with ample nutrients (Dodds and Gudder 8 1982; Higgins et al. 2008). There is experimental evidence that Cladophora grows best under high 9 concentrations of both N and P (e.g., Rosemarin 1982). Experimental enrichment of both N and P 10 performed in situ in Lake Michigan has led to extensive growth of Chaetophora, a close relative to 11 Cladophora (Carrick and Lowe 1988; 2007). 12 13 Occurrence ofCladophora in Lake Erie 14 15 Occurrences of Cladophora were reported in the Great Lakes as early as 1930 (Neil and Owen 1964). 16 The distribution of Cladophora appeared to expand through the Great Lakes from 1960-1975, and this 17 was attributed to large nutrient inputs in the nearshore regions of Lakes Huron, Michigan and Erie with 18 biomass ranging from 100 - 800 g dry weight/m2 (Auer et al. 1982). While the biomass declined during 19 the 1970s and into the early 1980s coinciding with the P abatement programs in the Great Lakes, its 20 abundance underwent a surprising upturn again in the mid-1980s and early 1990s (Higgins et al. 2008). 21 More recently, standing crops up to 700 g dry weight Cladophora glomerata!m2 have been observed in 22 shallow nearshore waters (0.5 -2m depth) along the northern shore of the Eastern Basin; its occurrence 23 in this location may be linked to the presence of suitable hard substrate as well as other factors. Hard 24 substrate also supported colonization of dense populations of dreissenid mussels (Dreissena polymorpha 25 and Dreissena bugensis), which may exacerbate the problem of Cladophora growth by increasing water 26 clarity and enriching local regions with excreted nutrients, especially readily available P as SRP (Heath 27 et al. 1995). Increased water clarity allowed Cladophora populations to develop to depths up to 20 m. 28 Recent studies indicate that tissue content of P in Cladophora (i.e., P-quota) is an important metric of 29 growth potential of this alga: tissue of <0.07 pg P/mg dry weight is unproductive; tissue of >0.20 pg 30 P/mg dry weight is considered to be highly productive, capable of producing significant biomass, likely 31 leading to significant sloughing and formation of large amounts of "beach muck" upon decomposition 32 (Higgins et al. 2005, 2008; Lake Erie Millennium Network 2016). The levels of P storage in algal tissues 33 appear to be useful indicators of aquatic ecosystem eutrophication and thus subsequent remediation 34 (Price and Carrick 2016). 35 36 Ecosystem Consequences ofCladophora Blooms 37 38 Cladophora often plays a key role as an "ecosystem engineer" (an organism that alters the environment 39 in a way that affects the other organisms present) and this can have both important positive influences as 40 well as potentially negative consequences. This alga can serve as a substrate for epiphytic algal and 41 bacterial assemblages, which may also contain invertebrates (Lowe et al. 1982; Stevenson and Stoermer 42 1982; Chilton et al. 1986). While it may not be fed upon directly by invertebrates and fish, as substrate it 43 indirectly provides food for upper trophic levels. It is generally found in shallow, nearshore 44 environments where turbulent wave action is common. Because of its turbulent environment, filaments 45 frequently break or slough off, forming mats that can wash ashore and decay to a foul smelling mass 46 (i.e., beach muck). The processes that lead to sloughing and decay of the standing crop are not well 47 understood, and a recent workshop (Lake Erie Millennium Network 2016) identified Cladophora 18 17cv1906 Sierra Club v. EPA ED 001523 00003570-00030 Science Advisory Board (SAB) Draft Report (2/27/17) for Quality Review - Do Not Cite or Quote. This draft has not been reviewed or approved by the chartered SAB and does not represent EPA policy. 1 senescence and decay as a necessary research topic. As this "muck" decays, it gives off noxious odors, 2 and provides a habitat for biting flies and a substrate for E. coll and the bacterium responsible for avian 3 botulism. Because of its ability to scavenge and store excess P, Cladophora has often occurred as a 4 nuisance alga, capable of growing to large standing stocks leading to beach fouling as large stands of 5 "muck." Although there is no stated limit of acceptable standing crop, it is generally considered that less 6 than 30 g dry weight /m2 is indicative of "good" conditions (Lake Erie Millennium Network 2016). 7 Biomass density of greater than 50 g/m2has been suggested as the threshold for the onset of problem 8 conditions (Auer et al. 2010). 9 10 The Great Lakes Cladophora Model (GLCM) 11 12 The Great Lakes Cladophora Model (GLCM) is a mechanistic, mass balance model with two state 13 variables, net algal biomass (growth minus respiration and sloughing) and stored P. The forcing 14 conditions are: available SRP, incident light intensity and temperature (see Appendix B-9 of Great 15 Lakes Water Quality Agreement Annex 4 Objectives and Targets Task Team Modeling Subgroup 2016). 16 The model was calibrated by direct observation in the field (Lake Huron) and laboratory studies; it was 17 confirmed by comparing the fit of model predictions to observations in Lake Michigan. Cladophora 18 growth may be linked to SRP content in the overlying water column and ultimately with the P-quota. 19 The SRP in the overlying water column is influenced by local inputs from nearby tributaries, as well as 20 the presence and density of dreissenid mussels (Higgins 2004). Therefore, a scientifically-sound model 21 must incorporate site-specific factors, including local hydrodynamics. 22 23 Sensitivity analysis has indicated that the model is most sensitive to the minimum cell P-quota, the 24 maximum growth rate and the maximum respiration rate; it is marginally sensitive to parameters related 25 to phosphate uptake. Model curves for SRP vs. maximum standing crop and SRP vs. stored P content 26 show that SRP of 0.9 pg P/L would yield a maximum standing crop of 30 g dry weight/m2 and a stored 27 P content of 0.075 percent P. That is, 0.9 pg P as SRP/L would yield an acceptably low standing crop 28 and low growth potential for Cladophora. This level of SRP has been related to TP concentrations and 29 total P load to Lake Erie via load-response curves derived empirically and illustrated in Figures B9-2 30 and B9-3 in Appendix B-9 of the Annex 4 Ensemble Modeling Report (Great Lakes Water Quality 31 Agreement Annex 4 Objectives and Targets Task Team Modeling Subgroup 2016). This analysis 32 implies that Cladophora growth and P-quota could be controlled with a TP load reduction to 7,000 33 MT/year, or a load reduction of 25 percent. A goal of 40 percent reduction in TP load to Lake Erie was 34 recommended by the Task Team to attain other desired ERI thresholds; the implication of the GLCM 35 analysis is that meeting this goal would also reduce Cladophora growth. 36 37 The GLCM appears to provide a first order evaluation of Cladophora occurrence and initial predictions 38 regarding attainment of the ERI of reduction of Cladophora standing crops to acceptable levels with 39 little growth potential, as indicated by P-quota. However, further research must be completed to fill 40 knowledge gaps (listed in the key recommendations below) before recommendations for P load 41 reductions to reduce Cladophora growth can be developed with an adequate level of certainty and 42 scientific confidence. In this regard, it is particularly important to link the data needs of the model with 43 the data collection process. The EPA should evaluate data needs to reduce uncertainty in the model and 44 better predict algal growth and presence. 45 19 17cv1906 Sierra Club v. EPA ED 001523 00003570-00031 Science Advisory Board (SAB) Draft Report (2/27/17) for Quality Review - Do Not Cite or Quote. This draft has not been reviewed or approved by the chartered SAB and does not represent EPA policy. 1 Key Recommendations 2 3 Short Term: 4 5 The GLCM should be calibrated and confirmed in the Eastern Basin of Lake Erie using existing 6 data. 7 8 Site specific factors, including local hydrodynamics, tributary inputs, mussel densities, and other 9 important drivers, should be incorporated into the GLCM. 10 11 Intermediate Term: 12 13 Current and future studies should include investigation of P load inputs from key tributaries (e.g., the 14 Grand River Ontario) and the relative significance of local inputs and open lake P on stimulating and 15 supporting Cladophora growth. 16 17 The process or processes that lead to sloughing (local hydrodynamics, algal senescence, etc.) and 18 eventual decay of Cladophora to "beach muck" need further investigation and likely need to be 19 appended to the GLCM. 20 21 The development of a spatial model linked to remote sensing information should be explored to 22 better understand Cladophora distribution. 23 24 The GLCM should be included in a broader whole-lake model to forecast the likelihood of 25 Cladophora growth along the shores. Consideration should be given to the possibility that as 26 hazardous algal blooms abate, the likelihood of Cladophora growth along the shores may be 27 increased due to improvements in water clarity and colonizable habitat. 28 29 Long Term: 30 31 The GLCM would be more useful if it could be applied to the diversity of important benthic algae 32 (e.g., Chara, Lyngbya, Spirogyra, etc.) that can cause similar problems in the Great Lakes. The 33 similarities and differences among these various species should be considered in order to provide an 34 adequate representation of the problems of nuisance benthic algae in general. 35 36 3.3. Nitrogen Control 37 38 The current nutrient strategy for Lake Erie focuses on limiting P loading to the Lake. However, the Task 39 Team has also recommended tracking tributary N loads to the Lake. The EPA has asked the SAB to 40 provide recommendations to help determine whether consideration of N control is warranted. 41 42 3.3.1. Determining Whether Nitrogen Control is Warranted 43 44 Charge Question 4: What recommendations can the SAB providefor development ofan 45 approach to help determine whether consideration ofnitrogen control, in addition to 46 phosphorus, is warranted in Lake Erie to prevent harmful algae blooms and manage hypoxia? In 20 17cv1906 Sierra Club v. EPA ED 001523 00003570-00032 Science Advisory Board (SAB) Draft Report (2/27/17) for Quality Review - Do Not Cite or Quote. This draft has not been reviewed or approved by the chartered SAB and does not represent EPA policy. 1 particular, what questions, relationships, or research priorities related to nitrogen loading 2 (differentforms and sources) and in-lake cycling must be addressed? 3 4 The EPA and the European Commission have adopted a dual nutrient reduction strategy, including both 5 N and P, to prevent and reduce eutrophication of both inland and coastal waters (European Commission 6 2009; U.S EPA 2015) While P has always been considered the limiting nutrient for Lake Erie and most 7 other lakes, there is increasing evidence of the possible need for N control as well. The Baltic Sea can be 8 viewed as a model that exemplifies the strategy to control both N and P. Although the Baltic Sea has 9 some similarities to Lake Erie, most of the Baltic is estuarine but of low salinity. The importance of N 10 control in lakes is currently unsettled and is the subject of vigorous scientific debate (Paerl et al. 2016; 11 Schindler et al. 2016). While N control in Lake Erie may be premature, especially given its difficulty 12 and expense, additional research to determine the importance of N should be a high priority. In Lake 13 Erie, phytoplankton species composition and seasonal succession can vary with both N and P 14 concentrations and ratios, and thus phytoplankton biomass does experience co-limitation of N and P 15 during late summer and early fall (Moon and Carrick 2007). The phytoplankton species composition in 16 western Lake Erie has changed over time, likely reflecting changes in N and P inputs and cycles due to 17 changes in agriculture, the invasion of dreissenid mussels, climate change and other causes (Smith et al. 18 2015). N and P cycles are both coupled and uncoupled. Both nutrients are required in algal biomass in 19 roughly Redfield ratios (106:16:1 C:N:P), but are cycled differently through the environment. N can be 20 internally removed by a number of biotic and abiotic processes including: denitrification, anaerobic 21 ammonium oxidation (anammox) and transformed by dissimilatory nitrate reduction (DNRA), and 22 ammonia volatilization. Nitrogen cycling is likely influenced by the presence of dreissenid mussels 23 (Svenningsen et al. 2012) and this may in turn affect N:P stoichiometry and nutrient availability to 24 phytoplankton and macroalgae. Rates of internal N and P cycling are important as well as the loading 25 rates. As further discussed below, three of the Lake Erie models currently incorporate N cycling but 26 none address internal N and P pools, fluxes and ratios. 27 28 Needfor a Multiple Nutrient Strategy 29 30 There is increasing support for adopting a multiple nutrient strategy to reduce eutrophication, in both 31 fresh and salt waters (Conley et al. 2009; U.S. EPA 2015). For Lake Erie this means that, after the initial 32 consideration of P control, N and P control should be considered; this would be similar to the approach 33 taken for the Baltic Sea (Conley et al. 2011). Many documents urge additional control of external P 34 loading in the Lake Erie watershed (e.g., Stumpf et al. 2012; Michalak et al. 2013; IJC 2014; Scavia et 35 al. 2014; Dove and Chapra 2015; Powers et al. 2016); however, there is evidence that N control is also 36 needed (Chaffin et al. 2013; Davis et al. 2015). As previously noted, the toxic cyanobacterium 37 Microcystis, the major concern in western Lake Erie, does not fix N and therefore requires a fixed N 38 source. Microcystis can become N limited in late summer in western Lake Erie (Chaffin et al. 2013). In 39 addition, it becomes more toxic when nitrate is abundant in lake water (Harke et al. 2016). Furthermore, 40 Microcystis is very well adapted to obtaining P when levels of P are low in lake water because it can use 41 enzymes (e.g., alkaline phosphatase) to remove P from organic compounds (hydrolyze phosphate esters) 42 that are more readily abundant in lake water in comparison to simpler dissolved forms of P (Harke et al. 43 2016). While nitrate is the predominant form of N in Lake Erie and is highly mobile, there are also 44 lower levels of ammonium and other reduced N compounds (Chaffin et al. 2013) in the Lake. Since 45 these other reduced N compounds can be readily used by most cyanobacteria, they could be significant 46 contributors to blooms, even at low concentrations. 47 21 17cv1906 Sierra Club v. EPA ED 001523 00003570-00033 Science Advisory Board (SAB) Draft Report (2/27/17) for Quality Review - Do Not Cite or Quote. This draft has not been reviewed or approved by the chartered SAB and does not represent EPA policy. 1 The Maumee River drains a mostly agricultural watershed and discharges into the Western Basin of 2 Lake Erie, where annual cyanobacterial blooms have occurred since the mid-1990s. Stow et al. (2015) 3 document a decrease in total N (TN) load from the Maumee River since 2000 (despite concurrent 4 increases in discharge). They also provide evidence for decreased nutrient inputs in summer months 5 (May-July) in recent years, and seasonal shifts in the TN:TP ratio (decrease in March-April; increase in 6 September-November). Recent cyanobacterial blooms in the Western Basin are fundamentally different 7 from those occurring in Lake Erie prior to the P load reductions implemented in the 1970s. While most 8 blooms prior to the 1990s were comprised of filamentous, heterocystous cyanobacteria (e.g., 9 Aphanizomenon, a potential N-fixer), the modem blooms are comprised mostly of the non-N-fixing 10 genus Microcystis (Steffen et al. 2014). The inability of these cyanobacteria to fix atmospheric N 11 suggests an important role for external N loads from the watershed as well as an essential role of internal 12 N recycling mechanisms in modulating the total biomass and especially the composition of the 13 cyanobacteria community in the Western Basin. In addition, the toxin produced by Microcystis (and 14 other cyanobacteria), microcystin, contains a large proportion of N (10 N atoms per molecule), and 15 production of microcystin is strongly correlated with available N (Davis et al. 2015). This apparent N 16 problem in Lake Erie is not confined to the Microcystis blooms in the Western Basin. Indeed, algal 17 blooms in other parts of the Lake, including annual Planktothrix blooms in Sandusky Bay, Ohio (Davis 18 et al. 2015) and ongoing blooms of Cladophora (Davies and Hecky 2005), also involve non-N-fixing 19 algae. Furthermore, the proliferation of nuisance benthic algae (e.g., Cladophora and closely related 20 species) has been experimentally and empirically linked to available N and P enrichment in the Great 21 Lakes (See Carrick and Lowe 1988, 2007), 22 23 Low availability of N in lake water is associated with a switch between species of cyanobacteria (from 24 the occurrence of Microcystis to Anabaena). Thus, if N concentrations increase, the persistence of 25 Microcystis blooms could increase even if P concentrations are lowered. In addition, both inorganic and 26 organic N species can be important. Davis et al. (2010) found that growth of the toxic Microcystis 27 strains were enhanced by inorganic N whereas the non-toxic strains were stimulated by organic N. 28 Moreover, Zhang et al. (2015) found that microcystin production appeared to be regulated by total N and 29 NCL' but not by NCK or NH4+. Many phytoplankton species exhibit greater physiological response to 30 N:P than to either N or P separately. Numerous studies have shown that the availability of a combination 31 of N and P often results in higher cyanobacterial biomass than either nutrient added singularly (e.g., 32 Elser et al. 2007; Lewis and Wurtsbaugh 2008; Scott and McCarthy 2010, 2011). With increasing 33 frequency since 2002 there have been reports of algal blooms that are N and P co-limited or N limited, 34 especially during mid-to-late summer. In addition, increased availability of P from both external and 35 internal sources can enhance N limitation, especially under conditions where biological N2 fixation is 36 not possible. 37 38 Model Capability 39 40 The model descriptions in the draft Annex 4 ensemble modeling report suggest that, of the eight models 41 used to predict ERIs (not including the Cladophora model), only the Ecological Model of Lake Erie 42 (EcoLE), Western Lake Erie Ecosystem Model (WLEEM) and Estuary and Lake Computer Model 43 Computational Aquatic Ecosystem Dynamics Model (ELCOM-CAEDYM) include state variables for N. 44 None of the models appear to address internal accumulations of N and P by phytoplankton and 45 corresponding N:P ratios, which could be used to explore possible N-loading scenarios. 46 22 17cv1906 Sierra Club v. EPA ED 001523 00003570-00034 Science Advisory Board (SAB) Draft Report (2/27/17) for Quality Review - Do Not Cite or Quote. This draft has not been reviewed or approved by the chartered SAB and does not represent EPA policy. 1 Best Management Practices 2 3 The Maumee Basin is characterized by extensive row crop agriculture with tile drainage as well as 4 concentrated animal feeding operations. Agricultural Best management practices (BMPs) for P control 5 may help control N but may not be sufficient to attain the level of N control that could be needed. Best 6 management practices for P control often target sediments because much P is particulate. Nitrogen, 7 especially nitrate, is mostly dissolved and much more mobile, so if N removal becomes a goal to be 8 achieved, additional BMPs may be required to increase N removal. The agricultural activity of the 9 Mississippi River Basin leads to the hypoxia in the Gulf of Mexico. Studies of the Mississippi should 10 provide useful BMPs for the Maumee Basin. A recent study indicates that about half of the total N and P 11 in the Mississippi River Basin is contributed by agricultural (about 80% of the agricultural contribution 12 of N comes from fertilizer and 20% comes from manure; and about 55% of the agricultural contribution 13 of P comes from fertilizer and 45% comes from manure) (Alexander et al. 2008; Robertson and Saad 14 2013). There is some evidence that P loads from agricultural lands in Iowa have declined as a result of 15 the implementation of BMPs (Wang et al. 2016). 16 17 In order to evaluate the importance of N control in Lake Erie, research is needed to answer key 18 questions and understand important relationships. These are listed in the key recommendations provided 19 below. 20 21 Key Recommendations 22 23 Short Term: 24 25 Research should be conducted to determine the total N loadings entering Lake Erie over time and 26 space, including all the major species of N (oxidized, reduced, organic, and particulate). An N 27 budget should be developed for Lake Erie, especially the Western Basin, similar to that for Lake 28 Michigan (Han and Allan 2012). 29 30 Research should be conducted to show the reliability of current models for assessing the role of N in 31 Lake Erie eutrophication and whether the models can be improved (or new models developed) to 32 more completely incorporate N (including internal N and P pools and ratios). 33 34 Research should be conducted to understand the expected response of the four eutrophication 35 response indicators to N reduction in the improved models. 36 37 Intermediate Term: 38 39 Research should be conducted to determine: 1) how much of the external N loading can be removed 40 by internal removal processes; 2) the consequences of legacy N and P in the sediments and the 41 differences in internal cycling; and 3) the downstream consequences of not following a dual nutrient 42 strategy. 43 44 Research should be conducted to further understand: 1) the importance of concentrations and ratios 45 of N to other nutrients (P, but also Si) in directing or controlling ecosystem functions; and 2) the 46 balance in the ratio of N to P that would be best for ecosystem functioning. 47 23 17cv1906 Sierra Club v. EPA ED 001523 00003570-00035 Science Advisory Board (SAB) Draft Report (2/27/17) for Quality Review - Do Not Cite or Quote. This draft has not been reviewed or approved by the chartered SAB and does not represent EPA policy. 1 BMPs should be developed and applied to achieve additional N reduction in Lake Erie if needed. 2 Given the difficulty and expense of controlling and reducing N loadings, it is important to optimize 3 ecologically and economically the N sources to be reduced. 4 5 The EPA should determine the reduction in N loading that results from reduction of P loading. 6 7 Long Term: 8 9 Lessons learned from case studies of nutrient reduction in the Baltic Sea and other areas should be 10 applied to Lake Erie. This should include scientific, technical, policy and governance strategies. 11 12 3.4. Evaluation of Nutrient Reduction Targets 13 14 Inter-annual loading trends for the Maumee River are greatly influenced by annual variability in flows 15 (Great Lakes Water Quality Agreement Annex 4 Objectives and Targets Task Team 2015). The Task 16 Team identified a maximum flow below which the target load should be met and recommended the use 17 of flow-weighted mean concentrations (FWMC) as a benchmark for any given tributary load. The SAB 18 was asked to comment on the use of FWMC and any other approaches that should be considered to 19 account for inter-annual variability in hydrology in assessing progress in reducing tributary loadings of 20 P. 21 22 The Task Team also recommended development of a comprehensive adaptive management program that 23 would include annual routine monitoring of appropriate load, FWMCs and in-lake nutrient 24 eutrophication response indicators in conjunction with an intensive monitoring, research and operational 25 model application program every five years. The SAB was asked to comment on the adaptive 26 management approach. 27 28 3.4.1. Assessing Progress in Reducing Tributary Loadings of Phosphorus 29 30 Charge Question 5. Please comment on the use ofFWMC and any other approaches that should 31 be considered to accountfor inter-annual variability in hydrology in assessingprogress in 32 reducing tributary loadings ofphosphorus to the Lake. 33 34 In a stratified sampling program typically used in loading studies (e.g., Heidelberg University's 35 monitoring of Ohio tributaries), each sample does not have equal weight in determining the average. 36 Some samples may represent time intervals of one or more days, while others represent intervals of only 37 a few hours. Some form of sample weighting must be used to properly average tributary data collected at 38 such varying frequencies. In river systems, two types of mean concentrations can be considered: a time- 39 weighted mean concentration and a flow-weighted mean concentration (FWMC). The FWMC is the 40 preferred approach for calculating average concentrations in tributaries with variable flows. For 41 example, FWMC can be used to represent the average TP concentration in water discharged from the 42 Sandusky River to Sandusky Bay. To determine FWMC, the concentration in each sample is weighted 43 by both the accompanying time interval and the flow. FWMC represents the total load for the time 44 period (e.g., annually or March-July) divided by the total discharge for the same time period. 45 46 Flow Weighted Mean Concentrations are recognized as useful measures to address inter-annual 47 variability because they normalize the tributary P loading/delivery with respect to flow so that year-to- 24 17cv1906 Sierra Club v. EPA ED 001523 00003570-00036 Science Advisory Board (SAB) Draft Report (2/27/17) for Quality Review - Do Not Cite or Quote. This draft has not been reviewed or approved by the chartered SAB and does not represent EPA policy. 1 year performance (referring to nonpoint source nutrient controls) is not confounded by inter-annual 2 hydrology (Great Lakes Water Quality Agreement Annex 4 Objectives and Targets Task Team 2015). 3 The Task Team recommended using tributary FWMC as a benchmark to track progress in load 4 reduction. The SAB recommends reviewing all available monitoring outputs (e.g., discharge, flow, 5 concentrations, loads) from significant tributaries and multiple assessment approaches (including 6 FWMC and flow-adjusted concentrations) to evaluate efforts to control nutrient loadings. In addition, 7 uncertainty in the values derived using the flow-weighted or flow-adjusted approaches should be 8 explicitly quantified and presented, and detailed information on the implementation of P reduction 9 strategies should be collected to help identify the reasons for changes in P loads delivered to the Lake. 10 11 The use of FWMC analyses alone may "mask" elevated concentrations that could result in algal blooms. 12 Any analysis of the effect of nutrient concentrations should consider the response of the organisms 13 intended to be controlled. Nutrient concentrations (as affected by nutrient loadings) control organism 14 responses and the effect of temporal variability is an important consideration, especially for organisms 15 that have rapid life cycles and may respond quickly to shifts in nutrients. 16 17 The Heidelberg Tributary Loading Program (Heidelberg University 2016) collects and analyzes 18 approximately 450-500 water samples for pollutants at its monitoring stations each year. From that 19 information it calculates annual pollutant loads from each station and the loads of nutrients, sediments 20 and pesticides delivered to Lake Erie or the Ohio River. The Program makes the tributary data for most 21 of the monitoring stations publicly available, and also distributes a spreadsheet for data analysis that 22 calculates FWMC along with loadings for the nutrient parameters (TP, SRP, NOi + NOs', Total 23 Kjeldahl N or TKN) measured. Therefore, FWMC is a readily available statistic. For pollutants that tend 24 to increase in concentration as flow increases (like TP in the Maumee River), the FWMC will be greater 25 than the time-weighted mean concentration. 26 27 FWMC is considered by the Task Team to be a key tool for nonpoint nutrient control efforts (Great 28 Lakes Water Quality Agreement Annex 4 Objectives and Targets Task Team 2015). FWMC has 29 intuitive appeal because it is a concentration, which may be easier to understand and communicate than 30 "mass loading." FWMC is also useful for developing tributary inputs appropriate for the advanced 31 process-based models (WLEEM and ELCOM- CAEDYM) that require specification of both flow and 32 nutrient concentration in each tributary, instead of the tributary or basin-aggregate mass loadings used 33 by the simpler P mass balance models. An example showing how the FWMC approach can be 34 implemented is presented by Sether et al. (2004). The authors used this method to compare annual load 35 estimates of multiple water quality constituents across several sub-basins, accounting for differences in 36 average annual stream flow. Sether et al. (2004) also demonstrated an approach for calculating 37 confidence limits for FWMC estimates, explicitly acknowledging the uncertainty of these estimates and 38 recognizing that this uncertainty can influence how the results are interpreted in a management context. 39 The SAB notes that FWMC estimates for Lake Erie also should be accompanied by an appropriate 40 quantitative estimate of their uncertainty. 41 42 Annual discharge from the Maumee River is highly variable due to variations in the intensity, amount 43 and timing of precipitation. This variability is also an important factor leading to yearly differences in P 44 loads. Similarly, discharge from spring to early summer (March-July) varies annually, and inter-annual 45 variability during this period has been associated with variations in the size of the summer cyanobacteria 46 bloom (Stumpf et al. 2012; Obenour et al. 2014); therefore, tributary loadings during this "critical 47 period" merit particular attention. The Task Team has attempted to account for this confounding 25 17cv1906 Sierra Club v. EPA ED 001523 00003570-00037 Science Advisory Board (SAB) Draft Report (2/27/17) for Quality Review - Do Not Cite or Quote. This draft has not been reviewed or approved by the chartered SAB and does not represent EPA policy. 1 behavior by identifying a maximum flow below which the target load should be met and by 2 recommending the use of FWMCs to track progress for any given tributary target load. Examination of 3 Figures 9 (Maumee River discharge), 10 (TP FWMC and load) and 11 (SRP FWMC and load) in 4 Recommended Phosphorus Loading Targets for Lake Erie (Great Lakes Water Quality Agreement 5 Annex 4 Objectives and Targets Task Team 2015) suggests that similar trends are evident in FWMC and 6 loading, especially for 5-year running averages. It appears that appropriate filtering (e.g., 5-year running 7 average) is also a necessary component of assessing trends in Maumee River discharges, concentrations 8 and loads. Although the Task Team's use of FWMC has focused on the Maumee River, the calculation 9 should be considered for other Lake Erie tributaries that are monitored using stratified sampling 10 programs. 11 12 The SAB notes that FWMCs are distinct from flow-adjusted concentrations (FACs), another tool that 13 should be considered in assessing progress in reducing tributary loadings of P. FACs are the residuals 14 from a statistical model relating concentration to discharge flow. FACs are used to remove the 15 seasonality from tributary monitoring data, and for detecting annual trends in the data once seasonality is 16 removed. For example, flow-adjusted concentrations were demonstrated by Stow and Borsuk (2003) to 17 aid in assessment of nutrient TMDL implementation on the Neuse River. Helsel and Hirsch (2002) also 18 provide information on the flow-adjusted concentration method. 19 20 Stow et al. (2015) note that Maumee River discharge increased from 1984-2013, a pattern that has been 21 shown to be consistent with long-term precipitation increases. In order for FWMC to offer an accurate 22 assessment of progress in reducing tributary loadings of P to Lake Erie, the assessment must also 23 consider the long-term trends in precipitation and discharge, and the FWMC benchmarks must be 24 adjusted as necessary to compensate for such trends affecting nutrient loadings. Discussion by Stow et 25 al. (2015) is particularly relevant regarding the use of FWMC or other approaches that should be 26 considered to account for inter-annual variability in hydrology: 27 28 "While it is generally acknowledged that targets may be exceeded during years of 29 unusually high precipitation and tributary discharge, the use of load targets remains a 30 common management tool. However, Milly et al. (2008) highlighted the growing 31 recognition that, for variables such as tributary discharge, the assumption of stationarity, 32 in an era of uncertain climate change, poses management challenges. Our results, 33 indicating progressive precipitation and discharge increases in the Maumee River basin 34 and concurrent phosphorus input increases to Lake Erie, suggest that imposing fixed load 35 targets may require phosphorus concentrations to be persistently lowered to compensate 36 for increasing discharge, if the targets are to be achieved. As phosphorus load targets are 37 re-evaluated pursuant to the updated 2012 GLWQA, it may be appropriate to address the 38 possibility that continued discharge increases into the future may affect target attainment 39 even if phosphorus reduction strategies are successful." 40 41 This statement highlights the need for future collection of detailed information on the implementation of 42 P reduction strategies in each major watershed.7 Without this information, it will not be possible to 43 adequately identify the primary reasons for the observed changes (or lack thereof) in P loads delivered to 7 The Task Team identified a number of priority watersheds (Great Lakes Water Quality Agreement Annex 4 Objectives and Targets Task Team 2015). 26 17cv1906 Sierra Club v. EPA ED 001523 00003570-00038 Science Advisory Board (SAB) Draft Report (2/27/17) for Quality Review - Do Not Cite or Quote. This draft has not been reviewed or approved by the chartered SAB and does not represent EPA policy. 1 Lake Erie. This will limit the ability to adequately assess the effect of P reduction strategies in light of 2 other confounding factors such as those related to climate change. 3 4 The SAB also notes that, as previously discussed, P may not be the only factor affecting algal growth in 5 Lake Erie; N, silica or other micronutrients may also affect algal growth. If the focus of the Task Team 6 expands to consider the control of other nutrients, the same assessment approaches should be applied to 7 tributary monitoring data for those nutrients to evaluate efforts to control sources of nutrient loadings. 8 9 Key Recommendations 10 11 Short Term: 12 13 Uncertainty in the values derived using the flow-weighted or flow-adjusted assessment approaches 14 should be explicitly quantified and presented, and detailed information on the implementation of P 15 reduction strategies should be collected to help identify the reasons for observed changes in P loads 16 delivered to Lake Erie. 17 18 Intermediate Term: 19 20 All available monitoring data from significant tributaries and multiple assessment approaches should 21 be reviewed to evaluate efforts to control sources of nutrient loadings. The evaluation should include 22 relationships between hydrology, climate, agricultural practices, source control and trends in nutrient 23 loads and concentrations. 24 25 3.4.2. Adaptive Management Program 26 27 Charge Question 6. Please comment on the value ofapplying the existing eutrophication models 28 on an ongoing basis to periodically evaluate phosphorus loading targets and eutrophication 29 response indicators. What key elements should be included in the adaptive management 30 approach to successfully implement and evaluate our nutrient reduction goals for Lake Erie? 31 32 The SAB strongly endorses the development of an adaptive management program to evaluate the 33 responses of eutrophication indicators in relation to nutrient reductions consistent with the goals 34 developed for Lake Erie. The adaptive management program should involve an ongoing evaluation of 35 the efficacy of loading reductions in achieving the desired responses of the eutrophication indicators and 36 the adjustment of management actions, monitoring, and modeling in light of new information. This is 37 particularly important given uncertainties in the present P-reduction targets with respect to the expected 38 response indicator outcomes, as well as the potential for changing future conditions. An important 39 component of adaptive management is the opportunity to identify alternative management actions if 40 reductions in loadings fail to produce the desired or anticipated outcomes. The SAB provides the 41 following recommendations for adaptive management. 42 43 1. A standing adaptive management committee should be appointed. The SAB recommends that the 44 EPA formally appoint a standing adaptive management committee that is supported over the long 45 term. The committee should include technical experts (both academic and agency scientists) and be 46 charged with coordinating ongoing modeling and monitoring to evaluate progress towards meeting 47 loading targets and the desired values of the ERIs. The committee should consider alternative 27 17cv1906 Sierra Club v. EPA ED 001523 00003570-00039 Science Advisory Board (SAB) Draft Report (2/27/17) for Quality Review - Do Not Cite or Quote. This draft has not been reviewed or approved by the chartered SAB and does not represent EPA policy. 1 management actions and develop the necessary supporting science if reductions in nutrient loading 2 fail to achieve the desired outcomes as measured by the ERIs. Through this process, adaptive 3 management can usefully inform future management decisions. 4 5 2. A coordinated binational long-term monitoring strategy should be developed. It is critical to provide 6 support for stabilizing and enhancing long-term monitoring in order to assess whether loading and 7 ERI targets are being met. Consideration should be given to the following activities: 8 9 - Assessing available loading information and developing standardized protocols for loading 10 estimates, including correlation between P loadings from major tributaries (estimated from 11 hydrologic loads and FWMC of total P and bioavailable P) and ERIs; 12 - Maintaining current tributary monitoring capabilities (e.g., Heidelberg University) and adding 13 additional tributaries; 14 - Developing standardized protocols for monitoring, evaluating and reporting values of ERIs 15 (cyanobacteria; hypoxia; Cladophord) in relation to management objectives; 16 - Considering the potential for additional ERIs (i.e., chlorophyll a, biological endpoints such as 17 benthic organisms in hypoxic areas and general fish productivity; measuring the health and 18 diversity of fish communities, particularly Whitefish, Coregonus clupeiformis)\ 19 - Ensuring that measurements are made of those variables that are necessary for calibrating and 20 assessing the performance of models and for evaluating alternative management actions as 21 necessary (see recommendations below). 22 - Ensuring that measurements are being made of those variables that are necessary for 23 development of new or improved models (i.e., mechanistic models of sediment diagenesis, 24 nutrient flux, and sediment oxygen demand); 25 - Incorporating measurements that provide "early warning" for climate change impacts. 26 27 3. Recommended models should be used as part of the adaptive management process. As previously 28 indicated, it may not be necessary to run all of the models that were included in the ensemble 29 modeling effort. However, the SAB finds that models can be used as part of the adaptive 30 management process to both identify and evaluate alternative management actions. They can also be 31 used to identify data gaps and to run future scenarios. In particular, the SAB recommends that: 32 33 - Models be used to make annual predictions of ERIs (cyanobacteria, hypoxia and Cladophora) 34 and post-audits be conducted to evaluate these projections; 35 - Models be refined based on changing loadings and other new data; 36 - Estimates of uncertainty be improved in the models; 37 - Lake models be linked to upstream source functions via watershed models; 38 - Cases where models do not perform well be used to develop alternative hypotheses; 39 - Models be built into alternative hypotheses as appropriate. 40 41 4. Alternative management actions may be required. The attempt to manage eutrophication in the 42 Western Basin of Lake Erie by reducing external P loading by 40 percent is based on the 43 assumptions that: (1) external P-loading is the sole driver, or at least the overwhelmingly major 44 driver, of HABs, hypoxia, and Cladophora proliferation, and (2) reduction in external P loading will 45 result in a reduction of these responses. It should be recognized that nutrient reduction is a 46 management action that can be evaluated within an adaptive management program. Depending on 28 17cv1906 Sierra Club v. EPA ED 001523 00003570-00040 Science Advisory Board (SAB) Draft Report (2/27/17) for Quality Review - Do Not Cite or Quote. This draft has not been reviewed or approved by the chartered SAB and does not represent EPA policy. 1 the success of nutrient reduction in achieving the desired values of the ERIs, additional factors 2 beyond reducing external P loading might need to be identified and incorporated into the 3 management strategy. 4 5 An important task for the adaptive management committee is to propose alternative drivers for the 6 ERI's and to assess what monitoring/modeling/experiments could be conducted to most effectively 7 distinguish among them. This can be done using a more passive approach wherein hypotheses are 8 modified and tested iteratively by adjusting design operations (sometimes called "monitor and 9 modify") or by taking a more active approach such as setting up field manipulations to test 10 competing hypotheses. It is beyond the scope of this SAB report to develop a comprehensive list of 11 alternative hypotheses for Lake Erie eutrophication. However, the SAB suggests the following list of 12 issues that might be considered, along with the accompanying research, monitoring and modeling 13 tasks that would be useful for addressing each issue. The SAB offers these as a starting point for 14 further consideration and prioritization by the adaptive management committee. As part of this 15 process, it would be instructive for the adaptive management committee to consider what the 16 potential management response might be if a given alternative is found to be important. 17 18 Loading 19 20 It is not clear how effective BMPs applied at different times and places in the watershed will be for 21 reducing P, nor is it understood whether BMPs directed at P-retention will be effective for N 22 removal. 23 24 Research, monitoring and modeling: 25 - Characterize BMPs with respect to the geochemical form of nutrient runoff addressed, spatial 26 distribution, type of BMP and life cycle effectiveness. 27 - Compare N runoff in areas using different BMPs targeted at P control. 28 - Conduct small-scale experiments that quantify the efficiency of BMPs for reducing both P and 29 N. 30 - Link watershed models to in-lake models and run a suite of scenarios to evaluate the 31 effectiveness of using different combinations of BMPs over space and time. 32 33 Cyanobacteria 34 35 The timing and magnitude of cyanobacterial blooms may be affected by the stoichiometric balance 36 of N and P in resource supply because algal growth and nutrient demand can generate conditions 37 where N and P become co-limiting. In addition, it is important to understand the linkage between 38 cyanobacterial biomass and toxin production in order to effectively address the potential effects of 39 blooms. 40 41 Research, monitoring and modeling: 42 - Calculate N loading to compare with P (including N:P ratios) and bioavailable forms of N and P. 43 - Monitor key N constituents in the tributaries. 44 - Run N scenarios in models; potentially develop new models. 45 - Evaluate the seasonal timing of N loading. 46 - Consider conducting in situ experiments (limno-corrals) to evaluate N limitation in the field. 29 17cv1906 Sierra Club v. EPA ED 001523 00003570-00041 Science Advisory Board (SAB) Draft Report (2/27/17) for Quality Review - Do Not Cite or Quote. This draft has not been reviewed or approved by the chartered SAB and does not represent EPA policy. 1 - Measure toxins in a standardized, coordinated way. 2 - Evaluate correlations between particulate organic carbon (POC), chlorophyll a, cyanobacteria 3 and microcystin concentration. 4 - Develop models to explore relationships between P, N, phytoplankton community composition 5 and implications for toxins. 6 7 Hypoxia 8 9 A number of factors contribute to the potential for oxygen depletion and hypoxia in the Lake, 10 including the duration and magnitude of spring diatom blooms, the seasonal progression of 11 stratification, and the extent of sediment oxygen demand. Although many of these factors are 12 incorporated in current models, it would be useful to improve our understanding of the relative 13 importance of these drivers and their relationship to external nutrient loads. 14 15 Research, monitoring and modeling: 16 - Quantify diatom bloom magnitude and duration. 17 - Evaluate relationship between diatoms and seasonal N, P and silicon (Si) loading. 18 - Use models and empirical analyses to evaluate relationship between diatoms and hypoxia. 19 - Run model scenarios with varying stratification for a given P load. 20 - Expand models to include mechanistic processes to represent sediment nutrient diagenesis and 21 fluxes of inorganic nutrients and sediment oxygen demand. 22 - Collect site-specific data to support the development and calibration of models of nutrient 23 diagenesis and fluxes of inorganic nutrients and sediment oxygen demand. 24 25 Cladophora 26 27 Cladophora standing crop and productivity may be linked to internal P release from hypoxic 28 sediments or near-shore sources of P. In addition, the role of dreissenid mussels in promoting 29 Cladophora. proliferation is unclear. 30 31 Research, monitoring and modeling: 32 - Monitor near-surface suspended sediment concentrations to characterize the upper active mixed 33 layer in the Western Basin. 34 - Improve on current Cladophora modeling to include nearshore processes. 35 - Monitor dreissenid populations in the Central and Eastern Basins 36 - Compare light levels, N and P release in dreissenid beds (with and without Cladophora 37 removed) and control areas. 38 39 5. Future scenarios should be evaluated. Part of the reason that the loading targets for P are being re 40 evaluated is because of the changing response of the Lake over the past few decades. As part of the 41 adaptive management process, it will be important to understand the effects of climate variability 42 and other factors that may change in the future (Smith et al. 2015). The SAB recommends that the 43 adaptive management committee: (a) evaluate recent trends in the relationships between loading and 44 ERIs for evidence of increasing sensitivity or changes in seasonality (e.g., March-July) or spatial 45 patterns, and (b) develop a suite of future scenarios that can be explored using models. 46 30 17cv1906 Sierra Club v. EPA ED 001523 00003570-00042 Science Advisory Board (SAB) Draft Report (2/27/17) for Quality Review - Do Not Cite or Quote. This draft has not been reviewed or approved by the chartered SAB and does not represent EPA policy. 1 Potential scenarios that could be evaluated include: 2 3 - Climate change: increased precipitation and discharge; increased temperature; shorter duration 4 of ice cover. 5 - Anticipated changes in land use and population density. 6 - Regional economic development. 7 - Zero P input: (i.e., with no additional load, how long will it take for internal stores of P to run 8 out?). This is not so much an anticipated future scenario as a way to establish an end member. 9 - Combinations of the above that use integrated modeling approaches (e.g., combining watershed 10 landscape and hydrology models with Lake models). 11 12 6. The work proposed here should be structured to provide answers to the following questions on an 13 ongoing basis: 14 15 - Are load reduction targets being met? 16 - Are ERI's responding? 17 - Are ERI's being predicted accurately? If not, what alternative factors need to be considered? 18 - Are there additional management measures that need to be considered based on additional 19 understanding gained from evaluating alternative hypotheses? 20 - Which environmental and land use conditions are changing or likely to change in the future? If 21 so, what implications would such changes have for management? 22 23 In order to be in a position to address these questions the SAB recommends that the adaptive 24 management committee meet regularly and establish concrete targets for identifying key variables 25 to be monitored; deciding which alternative hypotheses are most important and what models/data 26 are needed to evaluate them; and agreeing on forecasting scenarios. This requires a long-term 27 institutional commitment to the process at the local and regional levels. 28 29 Key Recommendations 30 31 Short Term: 32 33 A standing adaptive management committee should be appointed to develop a program that 34 investigates alternative hypotheses and long-term forecasts in order to inform future management 35 decisions. 36 37 A coordinated binational long-term monitoring strategy should be developed. A standardized 38 monitoring protocol should be implemented among the different groups involved. The same 39 assessment approaches should be applied to tributary monitoring data for N and P to evaluate efforts 40 to control sources of nutrient loadings. 41 42 Alternative management actions for Lake Erie eutrophication should be identified and evaluated if 43 loading reductions fail to produce the desired management objectives. 44 31 17cv1906 Sierra Club v. EPA ED 001523 00003570-00043 Science Advisory Board (SAB) Draft Report (2/27/17) for Quality Review - Do Not Cite or Quote. This draft has not been reviewed or approved by the chartered SAB and does not represent EPA policy. 1 Recommended models should be used as part of the adaptive management process to identify and 2 evaluate alternative hypotheses. The models can also be used to identify data gaps and to run future 3 scenarios. 4 5 Future scenarios should be evaluated to understand the effects of climate variability and other factors 6 that may change in the future. 7 8 The proposed work should be structured to provide answers to key questions (e.g., are load reduction 9 targets being met, are ERIs responding, are ERIs being predicted accurately) on an ongoing basis. 10 11 The effectiveness of BMPs should be characterized with respect to type, spatial location in the 12 watershed, and life cycle effectiveness. 13 14 Intermediate Term: 15 16 Detailed information on the implementation of P reduction strategies in each major watershed should 17 be collected into the future (e.g., the areas of the landscape where strategies are being implemented 18 and P monitoring data showing trends in those areas). 19 17cv1906 Sierra Club v. EPA ED 001523 00003570-00044 Science Advisory Board (SAB) Draft Report (2/27/17) for Quality Review - Do Not Cite or Quote. This draft has not been reviewed or approved by the chartered SAB and does not represent EPA policy. 1 REFERENCES 2 3 Alexander, R.B., R.A. Smith, G.E. Schwarz, E.W. Boyer, J.V. Nolan, and J.W. Brakebill. 2008. 4 Differences in phosphorus and nitrogen delivery to the Gulf of Mexico from the Mississippi 5 River Basin. Environmental Science & Technology 42: 822-830. 6 7 Ali Ger, K. P Urrutia-Cordero, P.C. Frost, L-A Hansson, O Samelle, A.E. Wilson, and M. Lurling. 2016. 8 The interaction between cyanobacteria and zooplankton in a more eutrophic world. Harmful 9 Algae 54(2016): 128-144. 10 11 Auer, M., R. Canale, H. Grundier, and Y. Matsuoka. 1982. Ecological studies and mathematical 12 modeling of Cladophora in Lake Huron: 1. Program description and field monitoring of growth 13 dynamics. Journal of Great Lakes Research 8:73-83. 14 15 Auer, M.T., L.M. 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Harpole, H. Hillebrand, and J.E. Smith 29 2007. Global analysis of nitrogen and phosphorus limitation of primary producers in freshwater, 30 marine and terrestrial ecosystems. Ecology Letters 10(12), 1135-1142. DOI: 10.111 l/i.1461- 31 0248.2007.01113.x 32 33 European Commission. 2009. Guidance Document No. 23 - Guidance Document on Eutrophication 34 Assessment in the Context ofEuropean Water Policies. Technical Report - 2009 - 030, European 35 Commission. [Available at: https://circabc.europa.eu/sd/a/9060bdb4-8b66-439e-a9b0- 36 a5cfd8db2217/Guidance_document_23_Eutrophication.pdf] 37 38 Great Lakes Water Quality Agreement Annex 4 Objectives and Targets Task Team 2015. Recommended 39 Phosphorus Loading Targets For Lake Erie - Annex 4 Objectives and Targets Task Team Final 40 Report to the Nutrients Annex Subcommittee (May 11, 2015). [Available at: 41 https://yosemite.epa.gOv/sab/sabproduct.nsf//LookupWebProjectsCurrentBOARD/6393C0C5366 42 4172A85257F34005C3DC8/$File/Recommended+Loading+Targets+for+Lake+Erie_Task+Tea 43 m+report+May+2015 .pdf] 44 45 46 47 17cv1906 Sierra Club v. EPA ED 001523 00003570-00046 Science Advisory Board (SAB) Draft Report (2/27/17) for Quality Review - Do Not Cite or Quote. This draft has not been reviewed or approved by the chartered SAB and does not represent EPA policy. 1 Great Lakes Water Quality Agreement Annex 4 Objectives and Targets Task Team Modeling Subgroup. 2 2016. Annex 4 Ensemble Modeling Report, Peer Review Draft (May 2016). [Available at: 3 https://yosemite.epa.gOv/sab/sabproduct.nsf//LookupWebProjectsCurrentBOARD/6393C0C5366 4 4172A85257F34005C3DC8/$File/Annex+4+Ensemble+Modeling+Report+%28May+2016+Pee 5 r+Review+Draft%29.pdf ] 6 7 Han, H. and J. D. Allan. 2012. Uneven rise in N inputs to the Lake Michigan basin over the 20th century 8 corresponds to agricultural and societal transitions. Biogeochemistry 109:175-187. 9 10 Harke, M.J., T.W. Davis, S.B. Watson, and C.J. Gobler. 2016. Nutrient-Controlled Niche Differentiation 11 of Western Lake Erie Cyanobacterial Populations Revealed via Metatranscriptomic Surveys. 12 Environmental Science and Technology 50:604-615. 13 14 Heath, R.T., G.L. Fahnenstiel, W.S. Gardner, J.F. Cavaletto, S-J. Hwang. 1995. Ecosystem level effects 15 of zebra mussels (Dreissenapolymorpha): An enclosure experiment in Saginaw Bay. Journal of 16 Great Lakes Research 21:501-516. 17 18 Helsel, D.R. and R.M. Hirsch. 2002. Statistical Methods in Water Resources. Techniques of Water 19 Resources Investigations ofthe United States Geological Survey, Book 4, Hydrologic Analysis 20 and Interpretation. U.S. Geological Survey, Washington DC. 510 pp. 21 22 Heidelberg University. 2016. The Heidelberg Tributary Loading Program. 23 http://141.139.110.110/academiclife/distinctive/ncwqr/research/tribloading. [Accessed 24 November 16, 2016] 25 26 Higgins, S.N. 2004. The contribution of Driessena to the resurgence of Cladophora in eastern Lake Erie. 27 In: Cladophora Research and Management, Proceedings of a Workshop Held at the Great 28 Lakes WATER Institute, University of Wisconsin-Milwaukee, December 8, 2004 Milwaukee, 29 WI, 30 31 Higgins, S.N., E.T. Howell, R.E. Hecky, S.J. Guildford, and R.E. Smith. 2005. The wall of green: The 32 status of Cladophora glomerata on the northern shores of Lake Erie's Eastern Basin, 1995 33 2002. Journal of Great Lakes Research 31:547-563. 34 35 Higgins, S.N, S.Y. Malkin, H.E. Todd, S.J. Guildford, L. Campbell, V. Hiriart-Baer, and R.E. Hecky. 36 2008. An ecological review of Cladophora glomerata (Chlorophyta) in the Laurentian Great 37 Lakes. Journal ofPhycology 44:839-854. 38 39 UC (International Joint Commission). 2014. A Balanced Dietfor Lake Erie: Reducing Phosphorus 40 Loadings and Harmful Algal Blooms. Report of the Lake Erie Ecosystem Priority. International 41 Joint Commission, Washington DC. 42 43 Jarvie, H.P., L.T. Johnson, A.N. Sharpley, D.R. Smith, D.B. Baker, T.W. Bruulsema and R. Confesor. 44 2017. Increased soluble phosphorus loads to Lake Erie: Unintended consequences of 45 conservation practices. Journal ofEnvironmental Quality 46:123-132. 46 35 17cv1906 Sierra Club v. EPA ED 001523 00003570-00047 Science Advisory Board (SAB) Draft Report (2/27/17) for Quality Review - Do Not Cite or Quote. This draft has not been reviewed or approved by the chartered SAB and does not represent EPA policy. 1 Jeppesen, E., M. Sondergaard, J.P. Jensen, K.E. Havens, O. Anneville, L. Carvalho, M.F. Coveney, R. 2 Deneke, M.T. Dokulil, B. Foy, D. Gerdeaux, S.E. Hampton, S. Hilt, K. Kangur, J. Kohler, 3 E.H.H.R. Lammens, T.L. Lauridsen, M. Manca, M.R. Miracle, B. Moss, P. Noges, G. Persson, 4 G. Phillips, R. Portielje, S. Romo, C.L. Schelske, D. Straile, I. Tatrai, E. Willen, and M. Winder, 5 2005. Lake responses to reduced nutrient loading - an analysis of contemporary long-term data 6 from 35 case studies. Freshwater Biology 50:1747-1771. 7 8 Lake Erie Millennium Network 2016. State ofKnowledge ofCladophora in the Great Lakes Workshop 9 (Executive Summary). [Available at: 10 https://yosemite.epa.gov/sab/sabproduct.nsf/F0511648B656303F85257FB800739B4E/$File/Cla 11 dophora+Workshop+Executive+Summary+-+May+10+2016+%28final%29.pdf ] 12 13 Lewis, W.M. Jr. and W.A. Wurtsbaugh. 2008. Control of lacustrine phytoplankton by nutrients: Erosion 14 of the phosphorus paradigm. International Review ofHydrobiology 93:446-465. 15 16 Lowe, R.L., B.H. Rosen, and J.C. Kingston. 1982. A comparison of epiphytes on Bangia atropurprea 17 (Rhodophyta) and Cladophora glomerata (Chlorophyta) from northern Lake Michigan. Journal 18 of Great Lakes Research 8:164-168. 19 20 Ludsin, S.A., M.W. Kershner, K.A. Blocksom, R.L. Knight, and R.A. Stein. 2001. Life after death in 21 Lake Erie: nutrient controls drive fish species richness, rehabilitation. Ecological Applications 22 11(3):731-746. 23 24 Maccoux, M.J., A. Dove, S.M. Backus, and D.M. Dolan. 2016. Total and soluble reactive phosphorus 25 loadings to Lake Erie: A detailed accounting by year, basin, country, and tributary. Journal of 26 Great Lakes Research (2016) http://dx.doi.org/10.1016/jjglr.2016.08.005 27 28 Matzinger, A., B. Muller, P. Niederhauser, M. Schmid, and A. Wuest, 2010. Hypolimnetic oxygen 29 consumption by sediment-based reduced substances in former eutrophic lakes. Limnology and 30 Oceanography 55(5):2073-2084. 31 32 Michalak, A. M., E.J. Anderson, and D. Beletsky. 2013. Record-setting algal bloom in Lake Erie caused 33 by agricultural and meteorological trends consistent with expected future conditions. 34 Proceedings ofthe National Academy ofSciences ofthe United States ofAmerica 110:6448 35 6452. 36 37 Milly, P.C.D., J. Betancourt, M. Falkenmark, R.M. Hirsch, Z.W. Kundzewicz, D.P. Lettenmaier, and 38 R.J. Stouffer. 2008. Stationarity Is Dead: Whither Water Management? Science 319:1 February 39 2008. 40 41 Moon, J.B. and H.J. Carrick. 2007. Seasonal succession of phytoplankton nutrient limitation in the 42 central basin of Lake Erie. Aquatic Microbial Ecology 48:61-71. 43 44 Neil, J.H., and G.E. Owen. 1964. Distribution, environmental requirements, and significance of 45 Cladophora in the Great Lakes. University of Michigan Great Lakes Research Division. 46 Publication 11:113-121. 47 36 17cv1906 Sierra Club v. EPA ED 001523 00003570-00048 Science Advisory Board (SAB) Draft Report (2/27/17) for Quality Review - Do Not Cite or Quote. This draft has not been reviewed or approved by the chartered SAB and does not represent EPA policy. 1 Obenour, D.R., A.D. Gronewold, C.A. Stow, and D. Scavia,. 2014. Using a Bayesian hierarchical model 2 to improve Lake Erie cyanobacteria bloom forecasts. Water Resources Research 50:7847-7860. 3 4 Paerl, H.W., J.T. Scott, M.J. McCarthy, S.E. Newell, W. Gardner, K.E. Havens, D.K. Hoffman, S.W. 5 Wilhelm, and W.A. Wurtsbaugh. 2016. It takes two to tango: When and where dual nutrient (N 6 & P) reductions are needed to protect lakes and downstream ecosystems. Environmental Science 7 and Technology 50(20):10805-10813, DOI: 10.1021/acs.est.6b02575 8 9 Powers, S. M., T.W. Bruulsema, T.P. Burt, N.I. Chan, J. J. Elser, P.M. Haygarth,, N.J. K. Howden, H.P. 10 Jarvie, Y. Lyu, H.M. Peterson, A.N. Sharpley, J. Shen, F. Worrall, and F. Zhang. 2016. Long 11 term accumulation and transport of anthropogenic phosphorus in three river basins. Nature 12 Geoscience 9:353-35. 13 14 Price, K.J., and H.J. Carrick. 2016. Effects of nutrient loading on phosphorus uptake by biofilms situated 15 along a stream productivity gradient. Freshwater Science 35:503-517. 16 17 Robbins, J., J.R. Krasowski, and S.C. Mozley. 1977. Radioactivity in sediments of the Greats Lakes: 18 post depositional redistribution by deposit-feeding organisms. Earth Planetary Science Letters 19 36:325-333. 20 21 Robertson, D.M., and D.A. Saad. 2013. SPARROW model used to understand nutrient sources in the 22 Mississippi/Atchafalaya River Basin. Journal ofEnvironmental Quality 42(5): 1422-1440. 23 24 Rosemarin, A.S. 1982. Phosphorus nutrition of two potentially competing filamentous algae, 25 Cladophora glomerata (L.) Kutz and Stigeoclonium tenue (Agardh) Kutz, from Lake Ontario. 26 Journal of Great Lakes Research 8:66-72. 27 28 Scavia, D., J.D. Allan, K.K. Arend, S. Bartell, D. Beletsky, N.S. Bosch, S.B. Brandt, R.D. Briland, I. 29 Daloglu, J.V. DePinto, D.M. Dolan, M.A. Evans, T.M. Farmer, D. Goto, H. Han, T.O. Hook, R. 30 Knight, S.A. Ludsin, D. Mason, A.M. Michalak, R.P. Richards, J.J. Roberts, D.K. Rucinski, E. 31 Rutherford, D.J. Schwab, T. Sesterhenn, H. Zhang, Y. Zhou., 2014. Assessing and addressing the 32 re-eutrophication of Lake Erie: Central Basin Hypoxia. Journal of Great Lakes Research 40:226 33 246. 34 35 Schindler, D.W., S.R. Carpenter, S.C. Chapra, R.E. Hecky, and D.M. Orihel. 2016. Reducing 36 Phosphorus to curb lake eutrophication is a success. Environmental Science and Technology 50: 37 8923-8929. 38 39 Scott, J.T., and M.J. McCarthy. 2010. Nitrogen fixation may not balance the nitrogen pool in lakes over 40 timescales relevant to eutrophication management. Limnology and Oceanography 55:1265-1270, 41 doi:10.4319/lo.2010.55.3.1265. 42 43 Scott, J.T., and M.J. McCarthy. 2011. Response to Comment: Nitrogen fixation has not offset declines 44 in the Lake 227 nitrogen pool and shows that nitrogen control deserves consideration in aquatic 45 ecosystems. Limnology and Oceanography 56(4) 2011:1548-1550. 46 37 17cv1906 Sierra Club v. EPA ED 001523 00003570-00049 Science Advisory Board (SAB) Draft Report (2/27/17) for Quality Review - Do Not Cite or Quote. This draft has not been reviewed or approved by the chartered SAB and does not represent EPA policy. 1 Sether, B.A., W.R. Berkas, and A.V. Vecchia. 2004. Constituent Loads and Flow-WeightedAverage 2 Concentrations for Major Subbasins ofthe Upper Red River ofthe North Basin, 1997-99. 3 Scientific Investigations Report 2004-5200, U.S. Geological Survey, Washington, DC. 4 5 Smith, S.D.P., P.B. McIntyre, B.S. Halpern, R.M. Cooke, A.L. Marino, G.L. Boyer, A. Buchsbaum, 6 G.A. Burton, L.M. Campbell, J.J. H. Ciborowski, P.J. Doran, D.M. Infante, L.B. Johnson, J.G. 7 Read, J.B. Rose, E.S. Rutherford, A.D. Steinman and J.D. Allan. 2015. Rating impacts in a 8 multi-stressor world: A quantitative assessment of 50 stressors affecting the Great Lakes. 9 Ecological Applications 25:717-728. 10 11 Steffen, M.M., B.S. Belisle, S.B. Watson, G.L. Boyer, and S.W. Wilhelm. 2014. Status, causes and 12 controls of cyanobacterial blooms in Lake Erie. Journal of Great Lakes Research 40:215-225. 13 14 Stevenson, R.J. and E.F. Stoermer. 1982. Abundance patterns of diatoms on Cladophora in Lake Huron 15 with respect to a point source of wastewater treatment plant effluent. Journal of Great Lakes 16 Research 8:184-95. 17 18 Stow, C.A., and M.E. Borsuk. 2003. Assessing TMDL effectiveness using flow-adjusted concentrations: 19 A case study of the Neuse River, NC. Environmental Science and Technology 37:2043-2050. 20 21 Stow, C.A., Y. Cha, L.T. Johnson, R. Confesor, and R.P. Richards. 2015. Long-term and seasonal trend 22 decomposition of Maumee River nutrient inputs to western Lake Erie. Environmental Science 23 and Technology 49:3392-3400. 24 25 Stumpf, R.P., T.T. Wynne, D.B. Baker, and G.L. Fahnenstiel. 2012.Interannual Variability of 26 Cyanobacterial Blooms in Lake Erie. PLoS ONE 7(8): 1-11. 27 28 Svenningsen, N.B., I.M. Heisterkamp, M. Sigby-Clausen, L.H. Larsen, L.P. Nielsen, P. Stief, and A. 29 Schramm. 2012. Shell biofilm nitrification and gut denitrification contribute to emission of 30 nitrous oxide by the invasive freshwater mussel Dreissena polymorpha (zebra mussel). Applied 31 and Environmental Microbiology 78:4505-4509. 32 33 U.S. EPA. 2015. Preventing Eutrophication: Scientific Supportfor Dual Nutrient Criteria.. EPA-820-S- 34 15-001 ed. Office of Water, U.S. Environmental Protection Agency, Washington, DC. 35 36 U.S. EPA Science Advisory Board. 2015. Early Advice on an Ensemble Modeling Approachfor 37 Developing Lake Erie Phosphorus Objectives. EPA-SAB-15-010. U.S. Environmental 38 Protection Agency, Washington D.C. [Available at: 39 https://yosemite.epa.gov/sab/sabproduct.nsf702ad90bl36fc21ef85256eba00436459/3032F06970 40 6B472385257E6F0063EAF7/$File/EPA-SAB-15-010+unsigned.pdf] 41 42 Wang, C., K-S. Chan and K.E. Schilling. 2016. Total phosphorus concentration trends in 40 Iowa 43 Rivers, 1999-2013. Journal ofEnvironmental Quality 45:1351-1358. 44 45 Wehr, J.D., R. Sheath, and J.P. Kociolek. 2015. Freshwater algae ofNorth America. 2nd edition, 46 Academic press, London, 1050 p. 47 38 17cv1906 Sierra Club v. EPA ED 001523 00003570-00050 Science Advisory Board (SAB) Draft Report (2/27/17) for Quality Review - Do Not Cite or Quote. This draft has not been reviewed or approved by the chartered SAB and does not represent EPA policy. 1 WHO (World Health Organization) 2003. Cyanobacterial toxins: Microcystin-LR in drinking-water. 2 Background document for preparation of WHO Guidelines for drinking-water quality. Geneva, 3 World Health Organization (WHO/SDE/WSH/03.04/57). 4 5 Yurk, J, and J.J. Ney. 1989. Phosphorus-fish community biomass relationships in southern Appalachian 6 reservoirs: can lakes be too clean for fish? Lake and Reservoir Management 5(2):83-90. 7 8 Zhang, D., Q. Liao, L. Zhang, D. Wang, L. Luo, Y. Chen, J. Zhong, and J. Liu. 2015. Occurrence and 9 spatial distributions of microcystins in Poyang Lake, the largest freshwater lake in China. 10 Ecotoxicology 24:19-28. 17cv1906 Sierra Club v. EPA ED 001523 00003570-00051 Science Advisory Board (SAB) Draft Report (2/27/17) for Quality Review - Do Not Cite or Quote. This draft has not been reviewed or approved by the chartered SAB and does not represent EPA policy. 1 APPENDIX A: THE EPA'S CHARGE QUESTIONS 2 3 Background 4 5 EPA Region 5 is co-leading a binational workgroup to develop and implement the Nutrients Annex 6 ("Annex 4") of the 2012 Great Lakes Water Quality Agreement (GLWQA) in accordance with Article 7 3(b)(i) of the GLWQA. Under Annex 4, the U.S. and Canada committed to address eutrophication issues 8 in Lake Erie by first establishing phosphorus objectives, loading targets and allocations for the nearshore 9 and offshore waters by February 2016, and subsequently develop phosphorus reduction strategies and 10 domestic action plans by 2018. A binational workgroup of Lake Erie scientists used a suite of models to 11 generate a series of load response curves in order to simulate the impact of phosphorus loads to 12 cyanobacteria biomass, hypoxia and Cladophora growth, and identify the phosphorus reductions needed 13 to meet the desired ecological condition for the Lake. EPA sought early SAB advice on the modeling 14 approach in December 2014. The SAB's feedback was considered in the subsequent deliberations by the 15 binational workgroup, and resulted in improved documentation of the uncertainties and sensitivities of 16 the models. The U.S. and Canada released the recommended binational phosphorus reduction targets in 17 June 2015 and sought public input during July and August. The phosphorus load reduction targets were 18 accepted by the U.S. and Canada on February 22, 2016, as follows: 19 20 To minimize the extent ofhypoxic zones in the waters of the central basin ofLake 21 Erie: a 40 percent reduction from 2008 loads in total phosphorus entering the 22 western basin and central basin of Lake Erie - from the United States andfrom 23 Canada- to achieve a 6,000 metric ton central basin load. This amounts to a 24 reduction from the United States and Canada of 3,316 metric tons and 212 metric 25 tons, respectively. 26 27 To maintain algal species consistent with healthy aquatic ecosystems in the 28 nearshore waters of the western and central basins of Lake Erie: a 40% percent 29 reduction in spring total and soluble reactive phosphorus loads from the following 30 watersheds where localized algae is a problem: in Canada, the Thames River and 31 Leamington tributaries; and in the U.S., the Maumee River, the River Raisin, the 32 Portage River, Toussaint Creek, the Sandusky River, and the Huron River, OH. 33 34 To maintain cyanobacteria biomass at levels that do not produce concentrations of 35 toxins that pose a threat to human or ecosystem health in the waters of the western 36 basin of Lake Erie: a 40 percent reduction in spring total and soluble reactive 37 phosphorus loads from the Maumee River in the U.S. 38 39 Further reductions in phosphorus may be necessary to address benthic nuisance algal growth and 40 shoreline impacts in Lake Erie's eastern basin. The Annex 4 Objectives and Targets Task Team will 41 meet later this year to reconsider the viability of developing a target for the eastern basin, given the 42 current state of the science on Cladophora and recent updates to the Cladophora growth model. 43 44 EPA is currently working with other federal, state and Canadian partners to develop a long-term plan 45 that will identify the monitoring, data and analyses needed to support implementation and evaluation of 46 these nutrient reduction goals as part of an ongoing, adaptive management approach. We are also A-l 17cv1906 Sierra Club v. EPA ED 001523 00003570-00052 Science Advisory Board (SAB) Draft Report (2/27/17) for Quality Review - Do Not Cite or Quote. This draft has not been reviewed or approved by the chartered SAB and does not represent EPA policy. 1 working to develop a binational phosphorus reduction strategy and domestic action plans which will 2 outline actions to be taken to achieve the targets. 3 4 Furthermore, a binational task team was formed under Annex 4 to initiate steps required to develop Lake 5 Ontario nutrient targets. That team is currently assessing the status of nutrients and eutrophication 6 impacts in Lake Ontario, identifying gaps in monitoring and modeling needed to support targets 7 development. The Lake Ontario Nutrients Task Team will benefit from lessons learned and 8 consideration of modeling approaches in Lake Erie. 9 10 Charge to SAB: 11 12 The EPA requests Science Advisory Board (SAB) review of the current modeling results and other 13 information used to inform development of the binational phosphorus reduction targets. We are seeking 14 a critical review so that we can ensure the Agency's ongoing efforts to develop, implement and evaluate 15 nutrient reduction goals for Lake Erie are based on sound scientific data, analyses, and interpretations. In 16 a spirit of adaptive management, we are most interested in SAB advice on enhancements to the 17 modeling approach, or new approaches to consider, that will help us proactively manage eutrophication 18 issues in Lake Erie in the long term. 19 20 Review Documents: The panel will review the following documents, which taken together explain the 21 process followed to develop the binational phosphorus loading targets for Lake Erie: 22 23 The Annex 4 Ensemble Modeling Report and Appendix B 24 Recommended Phosphorus Loading Targets for Lake Erie: Annex 4 Objectives and Targets Task 25 Team Final Report to the Nutrients Annex Subcommittee. May 11, 2015 26 27 Additional Documents: The following documents (and associated references), provide important 28 context and information related to our current efforts: 29 30 A Multi-Model approach to evaluating target phosphorus loads for Lake Erie. Scavia, DePinto 31 and Bertani. Journal of Great Lakes Research, in press. 32 State ofKnowledge ofCladophora in the Great Lakes. Executive Summary of Workshop held at 33 NOAA-Great Lakes Environmental Research Laboratory January 26-28, 2016 34 35 Charge Questions: 36 37 Approach for Developing Lake Erie Phosphorus Load Reduction Targets 38 39 Nine different Lake Erie models were used to predict the response of selected eutrophication 40 response indicators to different phosphorus load scenarios (see Table 1 in the Annex 4 Ensemble 41 Modeling Report). The eutrophication response indicators evaluated were (1) overall phytoplankton 42 biomass represented by chlorophyll a, (2) cyanobacteria blooms in the Western Basin, (3) hypoxia in 43 the hypolimnion of the Central Basin, and (4) Cladophora in the nearshore areas of the Eastern 44 Basin. Technical evaluation criteria were used to assess the capabilities of each model (see Section 45 2.3 and Appendix B of the Annex 4 Ensemble Modeling Report) and load-response curves were 46 generated for each eutrophication response indicator (see Section 3 and Appendix B of the Annex 4 47 Ensemble Modeling Report). A-2 17cv1906 Sierra Club v. EPA ED 001523 00003570-00053 Science Advisory Board (SAB) Draft Report (2/27/17) for Quality Review - Do Not Cite or Quote. This draft has not been reviewed or approved by the chartered SAB and does not represent EPA policy. 1 2 1. Please comment on whether the evaluation of the models was adequate to inform how model 3 results should be interpreted, given differences in model complexity and scale. Please identify 4 any additional analyses that may be needed to improve future development and interpretation of 5 the load-response curves for the eutrophication response indicators. 6 7 The document, Recommended Phosphorus Loading Targets for Lake Erie describes the process 8 followed by the Annex 4 Objectives and Targets Task Team to develop phosphorus loading targets 9 for Lake Erie. The document indicates that, to achieve a Western Basin cyanobacteria bloom 10 biomass threshold no greater than that observed in 2004 or 2012, 90% of the time, a spring Maumee 11 River load of 860 metric tons of total phosphorus and 186 metric tons of dissolved reactive 12 phosphorus is recommended. In addition, a 40% reduction in the spring load of total phosphorus and 13 dissolved reactive phosphorus from other Western Basin tributaries and the Thames River is 14 recommended. To meet a threshold of 2.0 mg/L or higher of hypolimnetic dissolved oxygen, an 15 annual total phosphorus load of 6,000 metric tons to the Western and Central Basins is 16 recommended. The Task Team did not recommend new phosphorus concentration objectives for the 17 open waters or the nearshore be identified at this time. 18 19 2. Please comment on whether the recommended targets reflect the best available information on 20 the drivers of cyanobacteria growth and seasonal hypoxia in Lake Erie and are appropriate to 21 meet the nutrient Lake Ecosystem Objectives defined in the GLWQA (as reflected in Table 1 on 22 page 7 of the document titled Recommended Phosphorus Loading Targets for Lake Erie). 23 24 Cladophora Growth 25 26 Additional phosphorus load reductions may be necessary to reduce nuisance levels of Cladophora in 27 the nearshore waters of the Eastern Basin of Lake Erie. The Annex 4 Objectives and Targets Task 28 team did not recommend a specific phosphorus objective or loading target to address Cladophora. 29 growth. EPA and Environment and Climate Change Canada convened a workshop in January 2016 30 to assess the current state of knowledge of Cladophora growth in the Great Lakes and identify 31 potential options for nutrient target development to be considered by the Annex 4 subcommittee. (Please 32 see the background document titled "State of the Knowledge of Cladophora in the Great Lakes. 33 Executive summary of Workshop held at NOAA-Great Lakes Environmental Research laboratory, 34 January 26-28, 2016.") 35 36 3. Please comment on whether scientifically-sound phosphorus load reduction recommendations to 37 address Cladophora growth in the Eastern Basin of Lake Erie could be developed at this time. 38 39 Nitrogen Control 40 41 While the current strategy focuses on limiting phosphorus loading to the Lake (total and dissolved 42 forms) as the key mechanism for controlling excessive algal growth, it is implied or assumed that 43 nitrogen loading likely will also be reduced through implementation of agricultural best management 44 practices, and the Task Team recommended that tributary nitrogen loads to the Lake be tracked in 45 addition to phosphorus. 46 A-3 17cv1906 Sierra Club v. EPA ED 001523 00003570-00054 Science Advisory Board (SAB) Draft Report (2/27/17) for Quality Review - Do Not Cite or Quote. This draft has not been reviewed or approved by the chartered SAB and does not represent EPA policy. 1 4. What recommendations can the SAB provide for development of an approach to help determine 2 whether consideration of nitrogen control, in addition to phosphorus, is warranted in Lake Erie to 3 prevent harmful algal blooms and manage hypoxia? In particular, what questions, relationships, or 4 research priorities related to nitrogen loading (different forms and sources) and in-lake cycling 5 must be addressed? 6 7 Evaluation of Nutrient Reduction Targets 8 9 The inter-annual loading trends for the Maumee River are greatly influenced by annual variability in 10 flows. The Objectives and Targets Task Team identified a maximum flow below which the target 11 load should be met and recommended the use of flow-weighted mean concentrations (FWMC) as a 12 benchmark for any given tributary target load. 13 14 5. Please comment on the use of FWMC and any other approaches that should be considered to 15 account for inter-annual variability in hydrology in assessing progress in reducing tributary 16 loadings of phosphorus to the Lake. 17 18 The Task Team recommended development of a comprehensive adaptive management program that 19 would include annual routine monitoring of appropriate load, FWMC, and in-lake nutrient 20 eutrophication response indicators in conjunction with an intensive monitoring, research, and 21 operational model application program every five years. 22 23 6. Please comment on the value of applying the existing eutrophication models on an ongoing basis 24 to periodically evaluate phosphorus loading targets and eutrophication response indicators. What 25 key elements should be included in the adaptive management approach to successfully implement 26 and evaluate our nutrient reduction goals for Lake Erie? 27 28 29 30 17cv1906 Sierra Club v. EPA A-4 ED 001523 00003570-00055