Actual field monitoring could be accomplished by summer-hire biologists led by permanent staff aquatic biologists. Most States employ aquatic biologists for monitor ing trends or issuing site-specific permits. A. Management personnel from each area within the standards and monitoring programs should be involved in this approach, including permit engineers, resource managers, and field personnel. The cost of developing biological criteria is a State-specific question depending upon many variables. Biological criteria provide an integrative assessment over time.
Biota reflect multiple impacts.
A. Dischargers are concerned that biological criteria will identify impairments that may be erroneously attributed to a discharger who is not responsible. This is a legitimate concern that the discharger and State must address with careful evaluations and diagnosis of cause of impairment. Although a discharger may be contributing to surface water degradation, it may be hard to detect using biosurvey methods if the waterbody is also impaired from other sources. This can be evaluated by testing the possible toxicity of effluent-free reference waters on sensitive organisms. Dischargers are also concerned that current permit limits may b ecome more stringent if it is determined that meeting chemical and whole-effluent permit limits are not sufficient to protect aquatic life from discharger activities.