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<br />COMMENTARY <br /> <br />2Jt <br /> <br />caveats necessary to addressing disadvantages with the ap- <br />proach. Fausch et al. (1990) repeated for each of the ap- <br />proaches the necessity of appropriate reference sites, and for <br />the more data intensive methods (the IBI consists of 12 <br />community attributes), the setting of a priori values, such as <br />the expected fish community for a relatively unperturbed <br />stream in specific ecoregion, by a competent fish ecol- <br />ogist/biologist/ichthyologist. They acknowledge that most <br />of the methods have been developed in the Midwest, and <br />problems with the methods were encountered when applied <br />to other ecoregions. The Ohio Environmental Protection <br />Agency has expended substantial effort in applying the IBI <br />method to water quality monitoring of that state (OEPA, <br />1988). Canton and Van Derveer (1997) and Van Derveer <br />and Canton (1997) did not use any of these methods to <br />substantiate that healthy fish communities occurred in <br />streams in southeastern Colorado. <br />Furthermore, their claim of no biological effects in Col- <br />orado streams cannot be confirmed from the information <br />given or referenced in their articles. Their statement seemed <br />to have fallen into the null fallacy trap: (1) There is no <br />evidence for adverse effects, versus (2) There is evidence for <br />no adverse effects (J. Skorupa, USFWS, personal commun- <br />ication, 1995), The null fallacy occurs when statement 1 (a <br />null finding) is given equal weight as statement 2 (a positive <br />finding). What often is overlooked is that a null finding <br />usually implies a lack of positive evidence in both direc- <br />tions-for effects or for absence of effects. <br />Contrary to the claim of Canton and Van Derveer (1997) <br />that there are no biological effects, there is evidence that fish <br />populations in several Colorado, Utah, and New Mexico <br />streams with elevated selenium concentrations are not <br />healthy. Findings in several NIWQP investigations indicate <br />that selenium concentrations are elevated sufficiently in <br />water, bottom sediment, and biota in the middle Green, <br />upper Colorado, Gunnison, Mancos, and San Juan rivers to <br />cause adverse effects in fish and wildlife (Butler et al., 1989, <br />1991, 1994, 1995; Stephens et al. 1988, 1992; Peltz and <br />Waddell, 1991; Blanchard et aI., 1993; Thomas et aI., 1997). <br />These rivers have several endangered fish including Colora- <br />do squawfish (Ptychocheilus lucius), razorback sucker <br />(Xyrauchen texanus), bony tail (Gila elegans), and humpback <br />chub (Gila cypha). Toxic effects from selenium and other <br />in organics are important factors in the decline of these <br />species and inhibition of their recovery (Hamilton, 1995, <br />1998; Buhl and Hamilton, 1993; Hamilton and Waddell, <br />1994; Waddell and May, 1995; Buhl, 1997; Hamilton and <br />Buhl, 1997a, b; Hamilton et al., 1996; 2000; Stephens and <br />Waddell, 1998). Moreover, the Recovery Program for the <br />Endangered Fish Species of the Upper Colorado River <br />Basin dropped one proposed floodplain restoration site for <br />endangered fish because elevated selenium concentrations <br />were present in water and biota, put six sites on temporary <br />hold pending outcome of ongoing selenium research with <br /> <br />endangered fish, and have three other sites on temporary <br />hold due to concerns about other inorganic contaminants <br />(P. Nelson, USFWS, written communication, 1997; Holley <br />and Weston, 1995; Stephens et al., 1995; Archuleta and <br />Holley, 1996). <br /> <br />4.4. Water/Diet Versus Sediment Uptake <br /> <br />Canton and Van Derveer (1997) state that "The chronic <br />toxicity threat posed by Se is primarily from dietary uptake, <br />which is a result of its propensity to cycle through the <br />sediment, where it enters the benthic-detrital food web and <br />ultimately causes reproductive impairment in fish and wild- <br />life through dietary uptake." The authors of this commen- <br />tary agree that the detrital pathway is one of the most <br />important pathways by which selenium is recycled. How- <br />ever, waterborne uptake is responsible for the entry of <br />selenium into the aquatic food web (Lemly and Smith, <br />1987). This critical point is not mentioned by Canton and <br />Van Derveer (1997). Uptake of selenium by bacteria, algae, <br />and aquatic invertebrates rapidly removes selenium from <br />the water column and concomitantly reduces water concen- <br />trations, which can give a false impression of low water- <br />borne selenium concentrations precluding adverse effects. <br />For example, Besser et al. (1993) reported that the biocon- <br />centration factor for algal accumulation of selenium from <br />water in absence of sediment was 5300-15,700 for sele- <br />nomethionine, 1440-1600 for selenite, and 428 for selenate, <br />and for daphnids these bioconcentration factors were <br />30,300-229,000, 570-3600, and 293, respectively. Canton <br />and Van Derveer (1997) have presented an incomplete dis- <br />cussion that does not address the importance of waterborne <br />selenium in food web residue dynamics, and do not present <br />data to support their underlying assumption that selenium <br />bioaccumulation and toxicity are more strongly linked to <br />the sediment pathway than the aqueous pathway. <br />Canton and Van Derveer (1997) further state that "Partic- <br />ulate Se, typically measured as either sediment, detrital, or <br />suspended particulate Se, has been recently identified as <br />a better predictor of adverse biological effects." However, <br />one of the key references they cited in support of this <br />statement (Presser et aI., 1994) does not promote sediment, <br />detrital, or suspended particulate selenium as the best pre- <br />dictor, but rather stresses the importance of defining sel- <br />enium contamination based on an ecosystem level <br />evaluation that includes the collection of a variety of food <br />chain organisms (T. Presser, USGS, personal communica- <br />tion, 1997). Presser and Piper (1998) have further illustrated <br />this point in a recent publication in which they apply a mass <br />balance approach to data available for systems impacted by <br />selenium in California. Their definition of mass balance has <br />been expanded beyond that documented in water-quality <br />loads because of the nonconservative behavior of selenium. <br />and consequently they recommend including a biotic <br />