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AUBREY CONISULTirMG. INC. 



^^^. 



2 November 1992 



BARNSTABLE COUNTY COMMISSIONERS 

 SCIENCE ADVISORY PANEL 



COMMENTS ON 



'FINAL WORK PLAN FOR PERFORMING A BIOLOGICAL IMPACT 



ASSESSMENT 



AND RELATED TASKS IN SUPPORT OF PREPARATION OF AN 



ENDANGERED SPECIES TECHNICAL MEMO" 



OCTOBER 1992 



The work plan proposed by A.D. Little (dated 24 July 1992; hereafter referred to as tlie 

 "Work Plan') was analyzed for its completeness and adequacy for its intended purpose. Tlie Work 

 Plan addressed the Endangered Species Technical Memorandum (ESTM) for the Boston Harbor 

 outfall from Deer Island. To f)erform the scientific analysis of this Work Plan, a Science Advisory 

 Panel (SAP ~ Table 1) was established by the Barnstable County Commissioners. The SAP is 

 composed of scientists having exemplary scientific credentials, and who are specialists in various 

 aspects of oceanography pertinent to the A. D. Little work plan. The work plan was reviewed 

 individually and then collectively in meetings and through correspondence. The comments of the 

 individual SAP members are attached as addenda. The overall comments of the SAP are contained 

 in this present document. 



SCOPE OF ANALYSIS: The scope of work for the SAP was defined by the County 

 Commissioners, specifically: 



1) After A.D. Little completes its Endangered Species Technical Memorandum, will EPA 

 be in a position to "insure" that the operation of the outfall pipe "is not likely to jeopardize the 

 continued existence of any endangered species or threatened species or result in the destruction or 

 adverse modification of habitat of such species which is determined by the Secretary, after 

 consultation as appropriate with affected States, to be critical?" 



2) In what ways is the Plan inadequate to address the question posed above in No. 1, and 

 what other specific tasks or inquiries would, in the opinion of the Panel, be necessary in order to 

 answer the question above. 



In the opinion of the SAP, following completion of the ESTM, EPA WILL NOT be in a 

 position to "insure" that the operation of the outfall pipe is not likely to jeopardize the living 

 resources. The panel came to this conclusion because of limitations in the scope and approach of 

 the ESTM, as well as the lack of availabiUty of data on key issues in studies which are ongoing and 

 which likely won't be completed by the time tlie ESTM is submitted. 



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