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Coastal Waters Project

January 29, 1996

Robin Alden, Commissioner
Maine Dept of Marine Resources
Marine Resources Laboratory
POB 8
West Boothbay Harbor, Maine 04575ę0008

Dear Commissioner,

Coastal Waters Project is an intervenor before the Maine Board of Environmental Protection concerning Site Law and NRPA permits for the proposed Sears Island Port. We are also participating in the NEPA review of the Supplemental Environmental Impact Statement for this project.

Our understanding is that Maine DEP has requested that MDOT supply additional information concerning the potential impacts to water quality and native species in Penobscot Bay from the discharge of ballast waterę and sedimentęcarried exotic species into bay waters by woodchip carrier ships using the port. This information will be included in the MDOT's application package for NRPA and Site Law permits for the Sears Island port proposal. Presumably MDOT will request an evaluation of these impacts from the Department of Marine Resources.

We strongly urge the Department of Marine Resources to thoroughly review this issue, as we believe an continuing dispersal of exotic biota into Penobscot Bay, as would occur with operation of a Sears Island port, has the potential to exert profound effects on Penobscot Bay's ecological structure and commercial and recreational fisheries.

A preliminary review of the scientific literature suggests that woodchip carrier ships can act as a significant vector for the introduction of exotic estuarine and marine species, including viruses, bacteria, diatoms, dinoflagellates, zooplankton, coelenterates, ctenophores and fish and shellfish larvae into the estuary that they discharge their ballast water and ballast sediments into prior to taking on a load of woodchips.

Plans call for the proposed Sears Island port to be used for woodchip export at a rate of two carrier ships per month. With each ship discharging up to 7 million gallons of ballast water and several hundred pounds of sediments into Penobscot Bay, the potential for significant modification of Penobscot Bay's ecosystem is very real. This could include displacement of native shellfish and finfish species and/or their forage species, increased toxic algae blooms, and other impacts.

Introduced marine species have caused measurable impacts to other estuaries, including the displacement of San Francisco Bay's native shellfish species with the Asian Clam, and the closure of shellfish farms in Australia. The Zebra mussel was introduced into the Great Lakes by ballast water discharge and has resulted in major changes to Great Lakes ecology as well continuing severe economic costs. The displacement of native Penobscot Bay shellfish and plankton species by exotic species from Asia or even other parts of the United states could have disastrous consequences for the regional commercial fishing industry. Such consequences include loss of forage species for larval lobster, clams, scallops, herring, cod and other commercially and recreationally exploited species larvae

While many ships carry out ballast water exchange during the voyage between the last port of call and the woodchip loading port, research has shown that because of safety concerns, such exchange does not exceed 40% of the total ballast water on board.

Moreover, such exchange has been found to result in the addition of mid ocean species into the ballast water that is discharged into the receiving waters at the woodchip loading port. There is also the question of the impacts to offshore ecosystems of ballast water exchange.

Chapter 372 "Policies and Procedures under the Site Location Law" of the Site Location of Development Law's regulations states that the Board of Environmental Protection "shall consider the size, location and nature of the proposed development in relation to:

A. The potential primary, secondary and cumulative impacts of the development on the character, quality, and uses of the land, air and water on the development site ├├and on the area likely to be affected by the proposed development;── and

"B. The potential effects on the protection and preservation of the public's health, safety, and general welfare."

Section 480ęD.3 of the Natural Resources Protection Act, 'Standards' requires that "The activity will not unreasonably harm any significant wildlife habitat, freshwater wetland plant habitat, aquatic habitat, travel corridor, freshwater, estuarine or marine fisheries or other aquatic life.

This section also states that compensatory mitigation may only be considered "if there is no specific biological or physical feature unique to the habitat that would be adversely affected by the proposed activity."

We believe these impacts could affect the fishing industry of greater Penobscot Bay. Consistent with Section 480ęE.1 of NRPA, the municipalities within that area should be notified of these potential impacts, and their comments considered.

Because of the potential severity of these impacts, we strongly urge the Maine Department of Marine Resources to give full consideration of these direct and indirect impacts of ballast¬borne exotic species on the Penobscot Bay ecosystem and related economic activities.

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