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3 

 EVALUATION 



The assessment document acknowledges repeatedly that most of the 

 essential processes and trophic linkages relevant to assessment of the potential 

 impact of the MWRA outfall on endangered species cannot be quantified. 

 Illustrative examples of this include the statements that (p.ES-11) 

 "understanding the factors which stimulate and maintain toxic algae (sic) 

 blooms remains elusive". That (p. 4-29), given lack of understanding of natural 

 population dynamics of the phytoplankton, their controlling mechanisms and 

 impact of anthropogenic modification, "it is difficult at this time to quantify the 

 exact risk of potential adverse effects on the phytoplankton community due to 

 discharges from the new outfall". That, (p,4-34) "Few data exist to quantitatively 

 assess the risk of adverse effects to higher trophic levels, i.e., protected species 

 and their prey, resulting from nutrients introduced at the proposed outfall". That, 

 (p. 4-39) "The risk that the outfall relocation would increase the frequency or 

 enhance the severity of [toxic] blooms cannot be quantified at this time given the 

 current limited understanding of bloom dynamics and the complexity of 

 controlling factors, including factors other than nutrients". The Assessment's 

 recommendation (p. 4-39) that "....further research and close field monitoring of 

 the discharge are highly recommended, in order to quantify and further refine 

 these prediction" acknowledges both the inadequacy of the data set to resolve 

 the assessment issues, and that the conclusions, at best, are speculative 

 guesses rather than "predictions', and which cannot be assigned statistical 

 confidence levels. Hence, in this reviewer's opinion, the conclusions reached 

 in the assessment are anecdotal. 



The EPA assessment is stated to be based on (p. 4-4) "...a weight-of- 

 evidence determination of the likelihood of a particular effect occurring". 

 Moreover, this (at least with regard to nutrient-related issues) is based (p. 4-4) 

 "...on examining all available information on the issue, including supporting and 

 opposing evidence" (see also p. ES-7), reported in the scientific literature and 

 the opinions of experts via personal communications. Conclusions attributed to 

 "personal communication " from T. Malone, without supporting evidence, are 

 frequent in the Assessment. 



It is not true, however, that "all available information" was assessed. 

 There is conspicuous absence of reference to many relevant papers in, for 

 example, the seven proceedings (totaling > 2500 pp) of International 

 conferences on harmful algal blooms. The Assessment (pp. 4-26-28) focusing 

 on potential outbreaks of the nuisance alga, Piiaeocystis pouchetii, present at 

 the outfall site and contiguous waters completely ignores the highly relevant 

 and extensive Dutch literature which documents its long-term occurrence 

 patterns there, linkage to eutrophication and its nutritional physiology. 

 Moreover, the authors of the Assessment incorrectly state (p. 4-28) that 

 Pfiaeocystisis a dinoflagellate! This serious error seriously challenges the 

 credentials of those who prepared that section of the Assessment dealing with 

 phytoplankton ecophysiology. There are significant differences in the 

 ecophysiology and environmental regulation of this nuisance alga and 

 dinoflagellates. The use of Phaeocystis as representative of dinoflagellates in 

 terms of the latters environmental regulation, including that by nutrients, is 

 inappropriate. This confusion is an additional constraint on the significant 

 admission of uncertainty by EPA underpinning its "weight-of-evidence" 

 conclusion expressed on p. 4-29: 



