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significance (if any) of the altered chemical form of the nutrients, and what are the chemical 

 pathways and rates for chemical transformations that alter these forms? 



10) The Assessment indicates that during summer conditions, the plume would be trapjjed 

 below the thermoclinc. However, the available data indicate that the surface mixed layer deepens 

 to 20-25 m in the late summer and early fall. Under these conditions, the nutrients would 

 discharge directly into the surface waten of Massachusetts Bay. This scenario is not discussed in 

 the Assessment 



1 1) If there is enhanced productivity in the area directly around the proposed outfall, what 

 is the probability of attraction of endangered species to this area for foraging, and what impacts 

 would such attraction have on these species? 



12) No discussion is presented of phosphate or silicate loadings from the proposed outfall 

 location, and their effect on phytoplankton dynamics. Will there be any effects on phytoplankton 

 dynamics from altered phosphate input into this deeper water site (as opposed to solely an increase 

 in nitrogen loading)? 



13) A method of drawing conclusions about various impacts, termed the "weight of 

 evidence" approach, has been applied in this Assessment. The weight of evidence methodology is 

 poorly defmed, non-quantitative, and subject to bias. NOAA should evaluate whether such 

 "weight of evidence" ranking is an acceptable methodology, particularly when performed by 

 proponents of a project, rather than by a panel of experts formed from individuals having different 

 but balanced biases. Weight of evidence may be appropriate for a National Academy of Sciences 

 panel consisting of individuals selected specifically to offset biases, but may not be as appropriate 

 for a project proponent and its consultants to apply, when the biases are clearly not balanced. 



SUMMARY 



The Assessment is a reasonably complete document meeting many of the objectives staled 

 in the Wo± Plan. Exceptions to this completeness are indicated in the accompanying attachments 

 as well as in the brief listing of results above. 



The attachments by the individual scientists on the SAP show a range of opinion regarding 

 the Assessment: two scientists find the Assessment relatively convincing and thorough, one states 

 generao agreement with the findings while providing some caveats, and rwo are in more serious 

 disagreement about whether the document can "insure" that the outfall pipe "is not likely to 

 jeopardize the continued existence of any endangered species or threatened species or result in the 

 destruction or adverse modification of habitat of such species which is determined by the 

 Secretary, after consultation as appropriate with affected States, to be critical." 



The following conditions, including both those of general concern and those unique to the 

 embayment, make it difficult to complete an unambiguous Assessment: 



• Lack of critical data on chronic, low-level nutrient input to partially enclosed coastal 

 embayments. 



• Lack of critical data on dose-response relationships for complex mixtures of 

 contaminants (including nutrients and toxins) in shallow coastal ecosystems. 



• Lack of numerical modeling results anticipated for the study, due to ongoing 

 development of the modeling techniques. 



