143 



SPECIFIC COMMENTS: 



The following comments deal with specific items in the EPA Biological Assessment. 

 As mentioned earlier, my review focused on the material directly concerned with 

 the endangered species, though all sections of the Assessment were reviewed. 

 Minor errors in spelling, grammar, etc. have not been included. Because the Execu- 

 tive Summary section did not contain supporting literature citations which would 

 enable checking, and should contain the same information which is in more detail in 

 later sections, my comments there are quite limited. 



Each comment below is keyed to the appropriate section of the Assessment by 

 page, paragraph, and line number (e.g.: P 1/1 1/L 1). I've counted paragraphs from 

 the top of each page, including partial paragraphs but excluding headers and sub- 

 headers. 



P ES-4/1 4/L 3: 'low of 100 animals'. See comment later (p. 6). 



P ES-4/5 5: This is a common problem throughout the Assessment. It confuses 

 right whale occurrence in the Bays with occurrence in the entire western Gulf 

 of Maine. In the Bays, earliest sightings are in February and the peak is in 

 April. The period stated in the Assessment more properly refers to the Great 

 South Channel, which, though off Massachusetts, is not part of the Bays 

 system. Jeffreys Ledge is also beyond the Bays, to the north. 



P ES-5/1 2/L 5: Why limited to "in inshore waters?" This sentence should more 

 properly read "It is estimated that one-third of right whale mortalities are 

 caused by ship collisions and entanglement in fishing gear." 



P ES-5/1 4/L 3&4: Should be "western North Atlantic" stock. There is probably a 

 separate breeding stock on the eastern side of the North Atlantic. 



P ES-13/1 3/L 5-7: This sentence, describing an overlap between right whales and 

 Alsxandrium blooms in the Bays, is likely in error. Firstly, "most of the feed- 

 ing population of right whales" is never in the Bays. The largest number of 

 individuals identified in the Bays in any year was 54 in 1986 (Kraus and 

 Kenney, 1991), which was an anomalous year with right whales resident 

 through the summer and fall. 54 is only about one-sixth of the knownidenti- 

 fied total. Excluding 1986 and 1987, the years with summer residency, over 

 91% of all right whale sightings in the Bays are in March-May, with 47.8% in 

 April (Kraus and Kenney, 1991), while 1 believe that red tides occur primarily 

 during the summer months. 



