y
data to support that eelgraas bode in Mains function any differently than eelgraas beds in other geographic locations.
* Maina dmr disagrees with the impact assessment and claims that the impacts are exaggerated.
DMR does not provida any persuasive rationale why wo should alter the impact assessment*  The joint evaluation uses only nu»ber« generated by Maine dot'a consultant.  To our knowledge, all parties agree that 0.6 acres direct fill or eelgraaB would be a certain loss*  The loss of an additional 8*8 acres due to indirect impaotai from shading, prop wash and back eddies is likewiee dafinite.  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 piar would uproot vegetation or increaae turbidity resulting in eelgrass lose.  Additionally, the report documents a 4 acre "temporary" loss of eelgraas due to dredging.  Eelgraes, 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 thie 4 acrec in the permanent loss column.
We agree that the question of reduced produ-: J.v.,"y acrva?,® is so&ewhat fluid.  However, it is quite poec, —'.a  h;.t ^owc;
areas labelled as suffering from reduced pro^uc;.:. ..^.y a^, l^. lo^t completely.  The analysis don® in the draft Marine impacts Report wae a credible attempt to quantity the larger indirect impacts»
* DMR states that the 4 acre Impact due to dredging way actually be less, because the impact will occur between October to May, when eelgrasa growth is slow.
Traditionally, dredging projects have been done in the late fail, winter or early spring to reduce oonfliuts with navigation, and anadrorooua fish runs.  The impact of winter dredging on eelgrass has never been definitively studied and it has be«n widely assumed that eelgrnss is less vulnerable in the winter becauae its growth is slowad.  A cold watar plant, eelgrass growth in Maine is primarily controlled by light.  Growth slows in fall 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 reBcrves. Dredging projects in th& winter can increase turbidity for extended periods and greatly reduce th« opportunity tor photosynthesis.  During a period of high growth, late