173 



The same critique applies to Section 2.3.2 (Predicted Effects of Toxic 

 Chemicals on Endangered Species), including ambiguous, if not 

 unachievable, reliance on "threshold effect' concentrations. The Work Plan, 

 by its focus on threshold effects and concentrations as an impact 

 assessment yardstick, applies a chemical (?EPA) criterion to trophodynamic 

 processes, rather than the relevant biological criteria which determine 

 chemical habitat impacts on endangered species. The threshold concept is 

 irrelevant to the ESTM and thv^^arts realization of the basic objectives of the 

 Work Plan. 



A conspicuous omission in the Cumulative Impacts (2.3.3) section is 

 failure to include watershed activity and altered use effects as part of the 

 assessment requirement. 



The inclusion of Model Predictions for Nutrients and Toxic Chemicals 

 (2.4) is commendable, but reliance on deriving threshold effects levels for 

 biological impact assessment vitiates projected uses of this model. Failure 

 to indicate which biological model will be used and coupled to the 

 hydrodynamic model is a shortcoming. 



RECOMMENDA VONS 



1). Data and analagous studies from other coastal regions and 

 experimental studies should be included in the Work Plan assessments to 

 allow utilization of a much larger data base and to overcome the serious 

 limitations of the data base available for the Massachusetts Bay ecosystem. 

 Many of the problems and hypotheses formulated in the Work Plan are of a 

 generic type and amenable to such analyses. 



2). Most of the hypotheses formulated are not testable, their resolution 

 requires important data not presently available and which can be obtained 

 only by experimentation. There are no shortcuts to the need to Initiate 

 suitably scaled experimental field studies and, on a smaller scale, on 

 selected processes relevant to the ESTM. These studies should be carried 

 out based on an ecosystem model, for which such studies would provide 

 appropriate rate constants. A minimum of five to ten years would be needed 

 for an integrated, multi-disciplinary experimental field program to lay the 

 basis for resolution of the ESTM issues. It must be recognized that the 

 issues raised in the document are at the cutting edge of contemporary 

 biological oceanography, and represent major, unresolved issues as to the 

 environmental and biotic regulation of the structure, dynamics and 

 persistence of marine ecosystems, which frequently have endangered 

 species at their apex. 



3). The present Work Plan should be dropped, and a new plan 

 developed which takes in account the limitations of the present plan, the 

 available data sets and ESTM needs. 



