86 



Dr. Charles Mayo 



Comments to ihe Committee on 

 Merchant Marine and Fisheries 



regarding 



Endangered Species Consultation 



on the 



Boston Hartxjr Outfall 



The following comments are presented in light of my substantial agreement with the 

 conclusions of the National Marine Fisheries Service's Biological Opinion and are intended 

 to express an ongoing concern with our lack of knowledge about the physical and biological 

 processes which influence the endangered species, especially the northern right whale. 



The Biological Opinion reasonably sets forth the circumstances which confront us as we in 

 good faith try to right the wrongs which have been visited on Boston Harbor for so many 

 decades. NMFS correctly recognizes what has been given little emphasis by governmental 

 agencies in the past • that coastal ecosystems which are so very important to human and 

 animal societies are unfathomably complex and, in spite of our efforts, nearly impossible to 

 truly manage. 



Absent very good predictive models of the ocean ecosystem and confronted by our need to 

 clean Boston Harbor, it may well be that the MWRA project is the best present-day solution. 

 But we must acknowledge, as this Biological Opinion does, that the consequences of the 

 project are not absolutely known. And, particularly in the case of such rare resources as the 

 right whales, we must do all that we can to understand the effects of the project on the 

 habitat and critical resources of the whale - we must assure that there is a sensitive 

 monitoring of the habitat, the whales, and the resources on which they depend so that we 

 may document and correct any changes in the whale's habitat should unpredicted and 

 detrimental changes occur. To this end the Biological Opinion recommends in general terms 

 the monitoring of right whale habitat. With regard to these recommendations I respectfully 

 encourage: 



1. That these recommendations be fully implemented. 



2. That monitoring begin immediately - our knowledge of any changes in the right whale 

 habitat will be only as good as our description of the conditions before the outfall is on line - 

 accurate description of the pre-outfall conditions and the response of the whales and their 

 resoyrces mujt begin now. 



3. That monitoring directed at right whales be tightly coordinated with ongoing Bays-wide 

 studies and be made a part of the discharge permit . 



4. That the design of whale habitat studies be constructed to make use of present knowledge 

 of the species with respect to scale, distribution, and occurrence of feeding and non-feeding 

 activities. 



