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problem, and leaves unclear which scales are being discussed. Somehow, the lack of impact on a 

 bay-wide scale is translated to a lack of impact on endangered species, when in fact a smaller 

 spatial scale impact could also affect the endangered species. Why the repon relies on baywide 

 scales instead of smaller scales for evaluating impacts is unclear. 



The repon also makes use of diludon estimates, comparing the existing outfall site with the 

 proposed outfall location. The shrinkage of dilution zones with the new outfall location is used as 

 justification for no impact The fact that the new outfall will have a smaller spatial impact is used 

 as justification for "no impact" required in the Endangered Species Act. Finally, the inference is 

 clear that the existing outfall has had no deleterious effects on the environment, so the proposed 

 outfall should be even better. I know of no data summary which shows the existing outfall has 

 not had serious effects on various aspects of the environment (phytoplankton, toxic blooms, 

 oxygen content). If such a review has not been done, then this argument is useless. 



It is disappointing that the computer models, while not perfect, could not be merged more 

 into this Assessment, given their strong billing in the Work Plan. 



GEOLOGICAL PROCESSES : V, .:' 



The original comments by the SAP on the Work Plan for the Biological Assessment 

 included some questions about geological processes.- These comments should be reviewed, 

 because the Assessment appears to ignore these processes completely in their review. One 

 statement, that resuspension will decrease toxicity, is clearly erroneous. Since the potential for 

 bioaccumulation was investigated in some detail, it would seem more balanced to discuss 

 geoaccumulation as weU, including the effects of resuspension and transpon to depocenters where 

 toxins might be concentrated. 



