104 



Since the outfall wiU be e divergent site, the nearfield advection associated with effluent discharge 

 ii unlikely to cause dense aggregations of copepods to fonn. Monitoring of this site for such 

 patches however is necessary to confirm this conclusion. Acoustical and optical instrumentation 

 can be used for such sampling which can be done in conjunction with acoustical tracking of the 

 plume. Trophodynainic enhancement of zooplankton populations could occur during late sununer 

 when water temperatures are warm and zooplankton generadon dmes ore 1-2 weeks, but the right 

 whales are not present in the Bays at that dme of year. 



Red ddes have occuned naturally for centuries. No dear evidence exists that nutrient pollution 

 increases the likelihood of these blooms. I agree with D. Andenon that there is no scientific basis 

 for concluding that relocation of the outfall will increase occurrence of red tides. Nonetheless, the 

 monitoring program should include a component to measure the abundance and distribution of 

 these species. 



Monitoring should also include high resolution time series measures of nutrient and plankton 

 abundance and taxonomic composition both hi the nearfield and in habitat areas. Moored 

 biological/physical arrays are recommended for this purpose. These moorings could be set along 

 transect lines to the east and south to examine distribution and abundance of plankton along paths 

 from the outfall site to Stellwagon Basin/Bank and Cape Cod Bay. Such moorings should include 

 ADCPs, CTDs, fluormeten, and optical zooplankton counters. I agree with NMFS that such 

 monitoring should also include sampling in copepod patches at the outfall site and in the 

 Stellwagon and Cape Cod Bay habitats. The monitoring program should also include analysis of 

 satellite imagery for IR and color (SeaWifs). Acoustical tracking of the plume is also 

 recommended. 



Other considerations: 



I agnse with the NMFS that contingency planning is essential. The contingency plan should 

 have an associated implementation schedule or time table which should be expeditious. If habiut 

 alterations are observed to be occurring at a rapid rate, it is important to have a contingency plan 

 that allows rapid cessation of the pollutant discharge or convenion to tertiary creatmenL Such a 

 contingency plan should meet the approval of the NMFS in consultation with other organizations 

 prior to permit issuance. 



I also agrw that NMFS should review the "Additional Studies" prior to issuance of the permit 

 to determine whether reinitiation of consultation is required. Regular meetings between EPA, 

 COE, and NMFS to consult on the endangered species and their habitats are deemed essential. 

 Chronic toxicity testing of the effluent is very imponant as is the establishment of limits on priority 

 pollutants. Rcquiremcms for further reductions in pollutant loadings are also recommended. 



Conclusion 



I concur with the findings of the NMFS Biological Opinion. The decision of no-jeopardy is 

 sound, provided the Conservation Recommendations arc adhered to by EPA. The only 

 modification to the NMFS recommendations I feel is essential is that the comparative study of 

 existing ocean outfalls be done prior to issuance of the .NPDES permit. 



