Q
data to support that aelgrass beds iti Maine function any differently than eelgraas beds in other geographic locations*
* Maine DMR disagrees with the impact assessment and claims that the impacts are exaggerated.
DMR does not provide any persuasive rationale why we should aXt«r th« impact acsesetaent* The joint evaluation uses only numbers generated by Maine dot's consultant. To our knowledge, all parties agree that 0*6 acres direct fill or eelgraas would bo a certain lo&e. The loss of an additional 8*8 acres due to indirect impaota from shading, prop wash and back eddies ia likewise definite. If the project goes forward a* described in the Draft Environmental Impact Statement, a shadow would be caet which will result in the loss of vegetation. Moreover, vessels operating in and around the pier would uproot vegetation or increase turbidity resulting in eelgrass lose. Additionally, the report documents a 4 acre "temporary" losa of eelgraas due to dredging. Eelgrass, once lost, is very difficult to restore especially in an area that will be an active port area with degraded water quality. The federal resource agencies doubt that this loss will be temporary and include thia 4 acrec in the permanent iobs column.
We agree that the question of reduced prociu-Uvitv ac?<:a^Q is Bonewhat fluid. However^ it ia quite poe6u-:.<a -r;-,t soa'& areas labelled aa Buffering from reduced preauo^^y a^j: '^ lo^t completely. The analysis done in the draft Marine impacts Report was a credible attempt to quantify the larger indirect impacts»
* DMR states that the 4 acre impact due to dredging may actually be leas, because the impact will occur between October to Way, When eelgrasa growth is slow*
Traditionally, dredging projects have been done in the late fall, winter or early spring to reduce oonfliota with navigation, and anadrowoua fish runs. The impact of winter dredging on eelgraae has never been definitively studied and it has be«.n widely assumed that eelgr&ss is leas vulnerable in the winter because its growth is alowod. A cold watar plant, ealgrasa growth in Maine ie primarily controlled by light. Growth slows in tall and early winter with diminished daylight and increases in late winter and early spring. In the winter, the plants, in effect, live on a thin margin. Shorter days mean less opportunity for photosynthesis and a greater dependence on reserves. Dredging projects in tne winter can increase turbidity tor extended periods and greatly reduce the opportunity tor photosyntheei». During a period of high growth, late