172 



«2. Could elevated nutrients increase seasonal phytoplankton 

 succession, species composition, patch density, biomass? 

 Ans: Yes. 



«3. Could altered successional patterns favor toxic phytoplankton 

 species over non-toxic ones? Ans: Yes. 



#4. Could nutrient-mediated changes in phytoplankton community 

 structure and function affect similar attributes of rooplankton, upon 

 w/hich right whales and primary prey of humpback and fin whales 

 depend? Ans: Yes. 



*i6. Could toxins from toxic phytoplankton blooms pass up the food 

 chain to humpback and fin whales causing death? Ans: Yes. 



Available literature supports these responses to five of the questions 

 falling within the expertise of this reviewer. The significance of these 

 responses is that the Work Plan has combined, if not confused, first 

 principles' type questions with habitat or endangered species-specific 

 questions and hypotheses. This is reflected in the tendency of the Work Plan 

 to formulate predicted effects questions as 'couW questions and the locally 

 endangered species issues as 'wouW questions. Moreover, the responses 

 to the 'couW questions can not be applied to the 'wou/rf' questions; that is, 

 the nine null hypothesis statements (Ho 1-9) to be evaluated. 



An approach suggested by the Work Plan is to assess the likelihood 

 that an impact is 1) likely to occur; 2) unpredictable, or 3) unlikely to occur. 

 The decisions are to be based on consideration of 'threshold effects", a 

 criterion of evaluation that has serious shortcomings, as pointed out above. 

 Moreover, evaluation of the nine null hypothesis statements can not be 

 achieved from a literature survey, nor from ongoing and projected field 

 surveys. The hypotheses require experimental approaches for resolution 

 (which have yet to be done in the region of concern); they are not tractable 

 from descriptive field surveys, nor testable from a literature review. Thus, the 

 Work Plan places very high reliance on evaluative procedures not 

 appropriate to the ESTM issues of concern. 



The potential occurrence of toxic phytoplankton bloom events 

 stimulated by outfall nutrient discharge has received much attention. 

 Remarkably, however, the Work Plan does not define the scope of the 

 needed assessment, in addition to toxic species events, it is irnportant to 

 assess potential noxious, harmful or nuisance species bloom occurrences, 

 but these are neglected in the Work Plan. Noxious, harmful and nuisance 

 species blooms may result in unsuitable food sources for herbivores preyed 

 upon by endangered species, their unsuitability being the consequence of 

 inadequate cell size, palatability or chemical composition. Assessment of 

 the potential occurrence of hypoxia and anoxia resulting from the 

 degradation of such species blooms avoided by herbivores also does not 

 appear to be a Work Plan element, nor assessment of carbon fluxes. The 

 latter is also relevant to the benthic habitat and its biota overlooked in the 

 Work Plan. 



