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•chieve the intended purpojc, because of lack of dinction, focus or competent implementation. 

 This observation strongly suggests that NMFS must clearly state the objectives of such studies, 

 and assure that the methodology is adequate to attain the objectives. In the case of discrimination 

 of effects of xenobiotics on strongly variable population dynamics in a highlv variable physical 

 environment, these objectives and approaches must be thought out carcfuUy and enunciated 

 completely. In my opinion, as discussed below, neither the adadonaJ studies nor the monitoring 

 components have been given this level of essential thought or written documentation. While I 

 agree in general with the Conservation Recommendations, in their present state they provide too 

 much opportunity for failure {o achieve objectives pertinent to the Endangered Species Act. In 

 addition, their vagueness may lead to condnueo debate, nther than resolving any debate 

 themselves. 



Since the Opinion's finding of no-jeopardy relies on the lack of available infonnation, 

 funire reviews must be done with improved iniormadon, to dispel some of the uncertainty. Thus, 

 the Conservation Recommendations must be well-focused and well-constrained, 



a) CONTINGENCY PLANNING: The contingency planning recommended by 

 NMFS, including the examination of mitigation measures such as tertiary irtatmem and reduction 

 of loadings, is essential. This process should not stop with a single examination now, but a 

 process should be established whereby mitigation options are continuously examined as new 

 technologies or new data become available throughout the lifetime of the outfall. Criteria for 

 acceptance or desirability of new or enhanced treatment alternatives should be developed. 



b) ADDITIONAL STUDIES (A-1 through A-8): Though in principal some of these 

 studies appear useful, some of the recommendations are so sparse that such studies may well prove 

 useless. In particular 



A-1: 3-D dilution model: Who will review the 3-D model? For what purposes? How will 

 this review fit into the consultation process? This "smdy" is entirely unclear. 



A-2: Partitioning of chemicals: imponant question. How will this be folded into the 

 consultation process? 



A-3: What is "particle focussing" methodology? How will this methodology help with the 

 consultation process? Why is there such a focus on lateral transport, as opposed to vertical 

 transport? Clearly the two pathways are linked. Who will review the USGS studies, and for what 

 purpose? How will this review be effected? Who will coordinate it? What regulatory powen will 

 be associated with this review? Since these studies will not be complete before anticipated Stan of 

 initial discharge, is NOAA recommending that discharge not take place until these studies are 

 completed? 



A-4: This comment sounds like a scientist with a method to sell (acoustics) developed it, 

 but it is stated without full benefit of the scientific basis behind such studies. What are the goals of 

 such studies? How will these studies provide "predictive information on the effects of the 

 proposed outfall plume on plankton patches along those horizons?" I agree that plume monitoring 

 is important, but I fail to sec any focused purpose in this clement of the modeling. To be useful, 

 acoustic monitoring must be a pan of an overall program, and cannot be a program in and of itself. 



A-5: Why focus on this single alternative prop9sed by Bova (1993)? Instead, a whole 

 suite of alternatives could be considered, This "study" should be part of the overall 

 recommendation P-3, and not singled out as a specific "study." I recommend incorporating this 

 alternative into P-3, and removing it as a separate "study." 



