137 



6 

 have been recorded in this region during this century, death being attributable 

 to unknown causes. The report does not acknowledge potential STX 

 contributions to this mortality, despite the fact that the fin whale diet is similar to 

 that of the humpback. The apparent failure to record a "death of a right whale 

 due to STX in Canadian waters where these blooms occur at greater frequency 

 and in proximity to summer feeding areas" (p. 4-41) is seemingly invoked as 

 support for the improbability of morbid vectoring of STX to cetacean 

 populations. 



The report (p. 4-38) refutes the possibility of nutrient regulation of blooms 

 by citing the 1976 anoxic outbreak of Ceratium tripos in New York Bight. This 

 bloom, as all those familiar with this anoxic event know from published 

 literature, cannot be attributed to nutrients. In citing this bloom as not supportive 

 of the nutrient-regulation hypothesis, the authors fail to recognize that red-tide 

 blooms which occur in frontal systems or on the continental shelf differ from 

 those closer onshore in that the latter are heavily influenced by nutrient 

 conditions, whereas the former are more heavily influenced by water column 

 physics. The New York Bight Ceratium bloom outbreak is, therefore, not 

 relevant to the issue. The authors also placed heavy weight on Malone's 

 personally communicated, but unsubstantiated view (p. 4-38) that he "has 

 observed that many (if not most) coastal systems subject to increased nutrient 

 loading have not experienced an increase in the frequency of toxic or nuisance 

 algal blooms". There is substantial contrary evidence. 



The authors' general misunderstanding of bloom dynamics issues is also 

 illustrated by their representative conclusion (p. 4-38) "that changes in the 

 frequency or extent of toxic blooms with the relocated outfall are not likely". 

 What is meant by extent is obscure, but the authors fail to consider the effects of 

 elevated nutrient delivery from outfall discharge on the magnitude and duration 

 of the toxic Alexandrium tamarense blooms which currently occur in the region 

 of the proposed outfall site, for example. They conspicuously fail to incorporate 

 into their analyses the buoyant surface plume entrainment of toxic Alexandrium 

 tamarense observed by Franks and Franks and Anderson (whose papers are 

 cited) and shown to periodically pass through the proposed outfall site. The 

 potential effects of such bloom enhancement and downstream dispersal of 

 larger toxic bloom populations resulting from injections of outfall nutrients into 

 the entrainment watermasses are completely ignored. The authors' 

 acknowledgement that bioom dynamics, species selection and community 

 structure are under multifactorial control prompts them to dismiss nutrients as 

 not playing a significant role in regulating such processes (see p. 4-36-39). 



The apparent procrustean bias to dismiss the potential for nutrient 

 induced changes in, and altered phytoplankton dynamics, therefore is evident 

 in the general approach of the Assessment to muster exceptions to such 

 regulation, its use of non-peer reviewed personal communications (i.e., 

 opinions), and in its exclusion of numerous reports documenting nutrient 

 modified effects will potentially occur. 



The accompanying "weight-of-evidence" approach used to prepare this 

 report applies an anecdotal approach at the expense of the scientific 

 assessment required. Frankly, 1 do not know whether the proposed outfall siting 

 will be beneficial, without effect, or be detrimental to the endangered species in 

 question. However, 1 strongly disagree that the EPA Biological Assessment has 



