93 



4. The MWRA should be required to address the effect of growth on the sewage 

 system and its future capacity. The Opinion's findings are based upon specific flow 

 assumptions, and it notes the lack of consideration given to growth in the volume 

 of effluent. The projected growth in the service area should be analysed, emd the 

 time over which this capacity is projected should be identified. 



Full and effective implementation of these recommendations and those in the 

 Opinion will require additional funds, We believe these costs should not be borne 

 solely by the MWRA ratepayers. The protection of Massachusetts and Cape Cod bays 

 and their resources are a national and statewide concern, and thus the costs of 

 protective measures must be shared. 



In closing, I would note that neither the Biological Opinion nor the consultative 

 process which preceded it, has addressed the difficulty of assessing Impacts In a 

 remote location BEFORE IT IS TOO LATE. While we would all agree that dead 

 whales as a measure of adverse impact is not acceptable, it is unclear as to what the 

 appropriate indicators are and how they arc to be measured. We are still left with 

 the critical question unanswered: How do we prevent harm from becoming 

 jeopardy, and jeopardy from becoming disaster? 



75-454 0-94-4 



