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SPECIFIC WORK PLAN COMMENTS 



Section 2.0: Technical Approach for Biological Impact Assessment: 



A literature review is proposed as the primary procedure by which to 

 assess potential habitat modification and associated changes In biotic 

 structure and their trophic linkages impacting endangered/threatened 

 species accompanying the proposed MWRA outfall location and effluent 

 discharge. While a literature survey is certainly an important relevant 

 activity, the Work Plan targets anecdotal, historical and descriptive elements ' 

 and the preparation of an inventory of past, present and future research 

 initiatives as the primary objectives of this activity. This is a static approach 

 not appropriate to the endangered species assessments. The most 

 probable endangered species are upper trophic level components whose 

 biology and ecology are impacted by dynamic, intricate trophic linkages 

 which must be quantified to assess impact. Conspicuosly absent in the 

 Work Plan, therefore, are directives that quantitative analyses are required, 

 rather than the proposed descriptive overview, or acknowledgment that the 

 proposed literature review and proposed consultations with recognized 

 experts can not replace the need for experimental approaches for testing the 

 Work Plan hypotheses, or to resolve impact issues. The Work Plan 

 specifically states (p. 3) that ' Much of the detailed and follow-up literature 

 reviewing will be performed as part of the biological impact assessment and 

 will focus on confirming or disproving potential linkages between causes 

 and effects." This Work Plan directive and the hypotheses listed appear to 

 approach the ESTM issues from a theoretical aspect, rather than from the 

 required specificity. The Work Plan provides no guidelines as to the quality 

 and quantity of the available data bank. Failure to include the Draft 

 Bibliography in the Work Plan prevents assessment of whether the included 

 items are adequate and sufficient for the purpose. To what extent will the 

 conclusions of the literature review be governed by the Work Plan 

 bibliography screened? 



The proposed Biological impact Assessment (2.3) seeks to define 

 potential adverse linkages between outfall discharge of nutrients and toxic 

 chemicals threatening endangered species. Will the evaluators be provided 

 with a list (beyond the four given on p. 12) of the specific toxic chemicals, 

 their concentrations and seasonal variability expected to be present in the 

 effluent? If so, what is the sounie of this data, and evidence that the data are 

 Indeed representative of the anticipated effluent discharge, given that the 

 outfall is not online? It is a common experience of experimentalists that 

 assessment of effluent enrichments on phytoplankton species composition, 

 abundance and productions is extremely difficult to quantify because of the 

 changing chemical composition of effluent, including its temporal and spatial 

 variability in its stimulatory and inhibitory properties. Further, what nutrients 

 are to be considered and predicted (see 2.4. p. 12)? Section 2.3.1 refers to 

 ■primary nutrients' defined (p. 6) as nitrogen, phosphate and silica. 

 However, it is well established that evaluations of outfall nutrient loading 

 require knowledge of the total concentrations of N. P and Si. Will the 

 dissolved and particulate organic pools of these nutrients be included with 

 the inorganic fractions in the analyses? Phytoplankton grovvdh is influenced 

 by the ratios of availability of nutrients (Redfield Ratio) and turnover times. 

 Will these aspects be considered as part of the 'primary nutrient' effects 



