onstrated. We hope that secondary treatment will reduce the levels 

 of those toxins. NMFS has recommended that EPA require expedi- 

 tious implementation of secondary treatment to reduce the toxins 

 as swiftly as possible. 



The biological opinion provides EPA with numerous conservation 

 recommendations to assess and minimize the potential for adverse 

 effects. The recommendations can be summarized under four broad 

 categories: first, a contingency plan should analyze reasonable 

 steps, including tertiary treatment; second, studies should be com- 

 pleted prior to the discharge of primary treated sewage at the out- 

 fall location; third, additional long-term studies and monitoring re- 

 quirements must be developed and implemented; and fourth, addi- 

 tional permit conditions to minimize adverse effects to listed spe- 

 cies should be considered. Our written testimony summarizes the 

 conservation recommendations that are all in the biological opin- 

 ion. 



All of this will require an additional commitment by the con- 

 cerned agencies and may require additional resources. This will not 

 come cheap. 



Reinitiation also is inevitable. Reinitiation will be spurred by re- 

 newal for the five-year discharge permit. It will also occur if the 

 monitoring plan is discontinued, if new information reveals effects 

 outside of the scope already analyzed, if the project is modified or if 

 a new species is listed. 



We have taken into consideration cumulative impacts also. We 

 are looking to identify cumulative effects caused by both long-term 

 use of the proposed outfall and any synergistic effects of other pol- 

 lutant sources occurring throughout the Massachusetts Bays 

 system. Of course, we are coordinating with the sanctuary, EPA, 

 all of the agencies working collectively on the recovery plans, and 

 the State. 



In conclusion, we are confident that, given the available scientif- 

 ic information, conditions in Boston Harbor and the bays will im- 

 prove as the new sewage treatment system is completed and put 

 online. However, we believe it is important and necessary to imple- 

 ment the conservation recommendations expeditiously. 



Thank you, Mr. Chairman. This concludes my testimony. John 

 Catena, Colleen Coogan, Jack Moakley and I will try to answer 

 your questions. 



[The prepared statement of Mr. Bigford can be found at the end 

 of the hearing.] 



Mr. Studds. Thank you very much, sir. 



Next we will hear from Mr. Richard Kotelly of Region I, EPA. 

 Mr. Kotelly. 



STATEMENT OF RICHARD KOTELLY, DEPUTY DIRECTOR, WATER 

 MANAGEMENT DIVISION, REGION I, ENVIRONMENTAL PROTEC- 

 TION AGENCY 



Mr. Kotelly. Mr. Chairman, I would like to thank you for the 

 opportunity to testify this morning. My name is Richard Kotelly. I 

 am the Deputy Director of the Water Management Division of 

 EPA, Region I. I have held that position for 17 years. I have been 

 employed by EPA since 1970. 



