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7 

 applied the necessary rigor in the collation, synthesis and extrapolation of 

 relevant data in support of the conclusions reached, and which are based upon 

 a quasi-scientific approach. Moreover, a basic question is ignored. How will 

 post-construction events due to natural variation be distinguished from adverse, 

 degradative or, even, favorable events resulting from effluent discharge at the 

 proposed outfall site? The latter is to be located in a highly variable region 

 physically, optically and subjected to incursions of entrained, toxic 

 dinoflagellates exposed to elevated nutrient discharge. The EPA 

 acknowledges (p. 4-20) the occurrence of "considerable variability". The need 

 to distinguish between natural variability vs. anthropogenic induced changes 

 (particularly if inimical) is essential to allow engineering solutions to mitigate the 

 latter effects, if necessary. 



The Assessment also suffers from the scailing factor applied as a 

 standard of change, i.e. whether baywide changes will occur. For example (p.4- 

 24), "dramatic baywide changes in nitrogen concentrations [from outfall 

 discharge] are not expected", and that "baywide changes in phytoplankton 

 communities are not likely to occur". While these conclusions may be 

 reasonable at the baywide boundary condition, the report does not assess the 

 nature and consequences of the anticipated nutrient gradients and associated 

 trophodynamic processes associated with localized and patchy nutrient 

 modified habitats. The report also excludes vectoring of STX, for example, to 

 endangered cetaceans on the grounds that they probably will not be attracted 

 to the enrichment plume. However, the report does not consider the potential 

 for migratory prey, such as mackerel and capelin (species reported to have STX 

 body burdens resulting from local red tide blooms) to ingest toxic prey in the 

 enrichment plume, and then to vector these toxins to offshore populations of the 

 piscivorous humpback and fin whales. This is a serious omission. 



There is repeated reference to the fact that Kemp's Ridley and 

 loggerhead turtles feed extensively on crabs (pp.ES-14, 3-56, 4-44, 4-46), with 

 the genus Cancer being "one of the main food items" of these turtles during 

 their summer visits locally, as well as extensive feeding of Ridley's on blue 

 crabs (Callinectes sapidus) (p. 3-56). The report concludes that these 

 endangered turtles will not be adversely affected by toxic algae since (p. 4-45) 

 'crabs of the genus Cancer, a preferred prey of both species, are not known 

 vectors for bioto_xin transfer". This is in error. Foxall et al. (1979) have 

 demonstrated SiX accumulation in the 'New England rock crab, Cancer 

 irroratus, feeding on toxic clams (Mya arenaria) which became intoxicated upon 

 filtering Alexandrium tamarense. Moreover, Callinectes sapidus, a dietary item 

 for the loggerhead turtle, also has been reported to become STX affected 

 during toxic dinoflagellate blooms (Wardle et al. 1975). Such omissions from 

 the Biological Assessment Report further compromise the claim (p.ES-7) that an 

 "examination of all available information" was made in arriving at an Impact 

 Assessment. Such omissions also compromise conclusions based on the 

 procedure EPA used (p.ES-7) to arrive at "a weight-of-evidence determination 

 of the likelihood of the particular effect occurring". 



