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the combined impacts in circulation models to derive the predicted concentrations, and test the 

 same sets of hxpotheses used for the outfall alone, although this is not actually stated directly. 

 One weakness" is the consideration of spatially cumulative impacts alone, with no mention of 

 cumulative impacts over the time scale of the probable lifetime of the proposed outfall. 



Section 2.4 includes the modeling as a separate task in suppon of the ESTM and/or BIA. Model 

 outputs of predicted concentrations of nutrients and toxics will be used in the estimation of 

 impact likelihoods. In fact, it is not at all clear why at least some ponions of this section were 

 included in the work plan. The modeling itself is apparently being done by someone other than 

 A.D. Little, and the Water Quality Criteria are not directly related to potential impacts on 

 endangered'species. A cleariy stated indication of how the model results would be used in the 

 assessment process would seem to me to be sufficient. 



In summar)', the work plan is largely adequate (with a few holes as noted) as a plan for 

 developing an Endangered Species Technical Memorandum, but not acceptable as a plan for 

 conducting a Biological Impact Assessment. There are many instances where it seems probable 

 that insufficient information exists in the literature to determine what the "threshold effects level" 

 for a given parameter may be, and the ESTM will likely have a significant number of us null 

 hypotheses where no estimation of rejection likelihood is possible. For the ESTM, that would be 

 acceptable. However, the full BIA process may well have to include some number of studies 

 to develop sufficient scientific information to go forward with testing of those hj^potheses. The 

 concept of "threshold effects level" itself seems to be pooriy defined, and perhaps completely 

 undefineable for anvihing other than direct toxic impacts on a single target species. Finally, the 

 acceptable level of impact will very likely differ between different endangered species. For 

 example, fin and humpback whale populations could very likely absorb some impacts which 

 might prove devastating for right whales - their populations are larger, they feed on more diverse 

 prey species, they have a wider selection of alternative habitats, they do not appear to use Cape 

 Cod Bay as an imponant nursery area, and they apparently possess much more genetic 

 variability. I would recommend that the BIA process include population viability analysis of 

 right whales (as well as anv other species suspected to have similar critically endangered status and 

 a high impact likelihood)" to help in definition of the levels of impact the population(s) might 

 absorb. 



