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A.6: I am not clear on what A-6 proposes. How is this different from P-37 Is this an 

 alternative analysis to use of the outfall pipe, to recommend development of a new sewage 

 treatment system? What EIS prepamcion is nsferred to here? 



A-7: I agree with this recommendadon. 



A-8: This is a key issue, and should be completed before the initiation phase. Give this 

 topic a high priority, as it has come up before in SAP recommendations in the past. However, 1 

 would not litnit the "study" to other outfalls, rather the focus should be on embayments that 

 experience long-term, chronic input of pollutants of various sons fix)m various sources, including 

 excess nutrients, pesticides, and the like. Thus, A-8 is a key recommendation which should 

 receive increased focus and an accelerated schedule. This "study" should include workshops, 

 perhaps an intemational symposium of experts worid-wide familiar with such issues, and refereed 

 papers and summaries. This cannot be just a paper study, since our knowledge of such chronic 

 pollution is increasing yearly, and much of the data tnay not be published yet. 



c) MONITORING : Monitoring is recommended for key issues. I can see no thread in 

 the monitoring proposed, and cannot find the goals of such monitoring stated anywhere. As a 

 country, the U.S. is good at monitoring (taking data); however, we arc poor in designing 

 monitoring programs that can resolve specific issues. Part of this poor design record is due to the 

 complexity of detecting human impacts in a highly variable natural system However, pan of this 

 poor design record is due to lack of effort at the beginning. I encourage the NCAA to assure cost- 

 efficient and effective monitoring recommendations, to assure some utility will come from the 

 effort. 



M-1) I agree with this recommendadon. 



M-2) What arc the purposes of seasonal physical and biological observations in the 

 farfield? What are the specific goals of such monitoring? Can we in fact achieve any desired goal, 

 given available ability to discriminate natural from induced changes? As written, this 

 recommendation is so non-specific as to be useless, except it may direct EPA to formulate a 

 specific faifield program, hopefully with carefully considered goals and methodology. 



M-3) Again, this recommendation sounds like input from a single scientist. The focus 

 here seems to be on use of a TECHNIQUE, rather than a scientifically defined GOAL. If the goal 

 is to verify a numerical model prediction, then die goal should be stated, and a carefully planned 

 suite of model verifications should be carried out. This recommendation misses the point, and 

 might lead to use of acoustic backscatter techniques for plume tracking, with no necessary 

 accompanying measurements to interpret those measurements. 



M-4) Once again, the goals of such monitoring are unclear. While this work will keep a 

 consultant or academic busy, the utility will come from clearly defined goals and methods. As 

 written, this roonitoring could be of little value without a well-defined plan, including comparisons 

 of such copcpod patches outside of the right whale high use area (controls or comparisons). 



M-5) This appears a reasonable requirement, though how such data will be interpreted is 

 unclear. The requirement may help track the endangered species in the bay, but how will it be used 

 to detemtine no-jeopardy compliance? Why would studies be conducted once every decade? What 

 are the appropriate time scales? This recommendation would seem to require more fine-tuning, as 

 do the other recommendations. 



M-6) In principle I agree with this requirement. However, I would like to see a specific 

 goal, such as "to determine appropriate water use and discharge regulations and enforcement in the 



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