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REVIEW OF A.D. LITTLE DOCUMENT ENfTITLED TINAL WORK PLAN FOR 

 PERFORMING A BIOLOGICAL IMPACT ASSESSMENT AND RELATED 

 TASKS IN SUPPORT OF PREPARATION OF AN ENDANGERED SPECIES 

 llECHNICAL MEMO' 



Dr. TED SMAYDA 

 21 SEPTEMBER 1992 



SUMMARY 



The A.D. LITTLE Work Plan for a Biological Impact Assessment of the 

 potential effects of the Boston Harbor outfall pipe on endangered species 

 has been reviewed. MACKEREL COVE ASSOCIATES has focused on the 

 suitability of the Work Plan to assess the potential impact that chronic 

 delivery of the anticipated nutrient and toxic chemical loadings vy/ill have on 

 phytoplankton dynamics, including toxic species events, and associated, 

 potential foodweb alterations which would influence the habitat, behavior 

 and ecology of endangered species. It is concluded that the proposed Work 

 Plan is inadequate to this task, and would not provide the necessary data 

 and analyses of the kind needed for preparation of an Endangered Species 

 Technical Memo (ESTM). While the scientific hypotheses to be assessed 

 are generally adequate, the proposed assessment procedures to test these 

 hypotheses are generally inadequate. Resolution of the biologically 

 relevant hypotheses requires experimentation, whereas the Work Plan 

 seeks resolution from retrospective literature analyses or ongoing 

 descriptive field studies. The proposed use of establishing 'threshold effect 

 concentrations' of nutrients and toxic chemical loadings as a major aspect of 

 assessment is inappropriate. Complex factor interactions, synergistic 

 effects, differential responses of the various life cycle stages, successional 

 changes and trophodynamic processes preclude effective use of the 

 'threshold' concept, which is basically a dose - response relationship 

 employing a single factor - single species matrix. Neither this approach, nor 

 the application of nutrient mass balance concepts will resolve the primary 

 issue to be assessed: whether biotic changes and altered trophodynamics of 

 key species, including prey of endangered species, will accompany outfall 

 discharge, and at what frequency, magnitude, time period, and persistence, 

 and whether such changes and alterations will be beneficial or detrimental 

 to endangered species. Instructions to Work Plan implementers are 

 inadequate, with definitions of key concepts not given; guidelines to the 

 depth and breadth of analyses to be carried out are ambiguous; qualitative 

 approaches are favored over quantitativeness; there are no statements as to 

 the limitations of the available data sets to permit preparation of the ESTM, 

 nor what selection criteria were used to prepare the Draft Bibliography to be 

 used in the analyses. Failure to include this bibliography with the Work Plan 

 has compromised assessment of the Work Plan's avoidance of data and 

 information selectivity which might skew the results of the ESTM analyses. 

 The ability of the proposed Work Plan to provide convincing, relatively 

 unambiguous findings is doubted. 



