Islesboro Island Land Trust
POB 182
Islesboro, Maine 04848

December 11, 1995

Robin Alden, Commissioner
Maine Department of Marine Resources
Marine Resources Laboratory
P.O. Box 8
West Boothbay Harbor, Maine 04575-0008

Dear Commissioner Alden:

I had the opportunity to read your letter of October 13, 1995 to the Federal Highway Administration and the Army Corps of Engineers. My initial reaction ranged from disbelief to horror and we feel compelled to respond

In general, your letter seemed more like a defense of the cargo port than a discussion of natural resources and their preservation. We saw little or no attempt to understand or appreciate the perspective presented in the National Marine Fisheries Service (NMFS), et. al., Evaluation. NMFS in concurrence with the U. S. Fish and Wildlife Service and the Environmental Protection Agency, has said that, "The proposed Sears Island cargo terminal would be one of the most damaging coastal development projects to occur in New England since modern environmental standards went into effect in the 1970s." Normally, one assumes that these federal resource agencies would be your allies, or at least share a common interest in resource maintenance. Your letter seemed to strike an antagonistic pose that, frankly, I could not understand and which I found inadequately supported. Where is DMR coming from?

The letter begins quite clearly by saying that DMR was established to conserve and develop Maine's marine and estuarine resources.

According to my dictionary, conserve means-.

1. a. To protect from loss or harm; preserve. b. To use carefully or sparingly, avoiding waste.
2. To economize.

Develop, on the other hand, is defined as,
1. To bring from latency to or toward fulfillment,
2. a. To expand or enlarge. b. To aid in the growth of, strengthen. c. To improve the quality of, refine.
3. To cause to become more complex or intricate; add detail and fullness to; elaborate.
4. a. To bring into being gradually. b. To set forth or clarify by degrees.
5. To come to have gradually; acquire,
6. To grow by degrees into a more advanced or mature state.
7. To come gradually into existence or activity

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8. a. To progress from earlier to later stages of a life, cycle. b. To progress from earlier to later or from simpler to more complex stages of evolution.

It is abundantly clear that the letter was not intended to further either conservation or development of Maine's marine and estuarine resources. The letter repeatedly justifies the cargo terminal proposal by explaining that specific resources in the surrounding area have been depleted or lost or degraded and that this is common and therefore neither cause for alarm nor reason to prevent the terminal construction.

For example, on page four you write, "Reference to previous impacts due to causeway construction are not relevant to the proposed project." We disagree. On the one hand, the issues associated with the causeway should indeed be of concern to managers of the marine and estuarine environment in part because the actions in this phase of the project illustrate an attitude of disrespect on the part of MDOT toward the ecological services being provided by the unaltered ecosystem and partly because the causeway area is part of a greater ecological whole.

You go on to say that clam habitat and resources were, in fact, destroyed but that these losses were mitigated by habitat construction. You surely are aware, however, that the monitoring reports being conducted for MDOT indicate "abundances of dead clams," in the words of the monitor, and that this decline in the persistence of live clams within the mitigated area continues as a trend since 1990, essentially representing the failure of the mitigation.

Another example of what seems to us to be an unfortunate lack of real concern for the natural resources issues involved here occurs in the last paragraph on page four. There you agree that "there will be some loss of habitat and lass of resources" but argue that the losses are not significant. While we would concur that a precise determination of loss of value due to the proposed cargo terminal is difficult or perhaps even impossible to determine, there is abundant evidence that the losses will be great (which we will discuss a bit more further along in this letter).

However, since we all acknowledge some degree of uncertainty regarding the precise levels of loss of value of the marine and estuarine resources at Sears Island should the terminal be built, the question should then revolve around how to confront this level of uncertainty. To our way of thinking, the wise position in matters of uncertainty is to maintain options; options and natural resource opportunities which building the terminal will foreclose on; options that would allow, if the terminal is not built, conservation and development of marine resources. I see absolutely nothing in the DMR stated purpose which suggests that the department should condone, even advocate for any losses or degradation of resources.

Paragraph two on page five argues that shellfish losses won't be so great. Paragraph three goes on in the same vein regarding other resources, saying there are very few lobster traps and very little urchin dragging in the area. Sea scallops, once prolific in this part of Pen Bay and a source of winter income to Islesboro residents, are now "not commercially abundant in the area" and, apparently, any effort to bring this resource back (to develop this resource, or any of the other resources once common to Penobscot Bay but now lost or severely depleted) is somehow no longer important.

Finally, on page six, in paragraph two, you contend that, since effects of the terminal construction on commercial species can not be quantified with any degree of certainty, the admitted losses due to the terminal should be ignored. It is absolutely amazing to me that someone given the charge to conserve and develop marine and estuarine resources in Maine could

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assume this attitude. Too many losses have already occurred in Maine waters. The fisheries problems in other industrialized or commercialized embayments along the east coast are devastating; whereas problems in less developed bays, where they exist, are far fewer. Our own resource agency, the Department of Marine Resources, won't stand up and advocate for the resources. In fact, your letter seems to suggest that DMR should ignore or even encourage proposals or activities that, using some science with which I, at least, am unfamiliar, are said to only create less than "significant" losses.

But I have more concern than simply with the general DMR position here. There are numerous statements in the letter that serve to diminish or question the function and therefore the value of eelgrass in the marine and/or estuarine ecosystem. Although I am certainly no expert, or even a scientist, these statements bother me considerably.

My wife is the seventh generation of Coombs to live on Islesboro and there are many others, Pendleton, Boardman, Hatch, who also trace their heritage back many generations. It is common local knowledge that quahogs, as they are called here, are only found near eelgrass meadows (not in the eelgrass but near the meadows), although it is also know that not all eelgrass meadows have quahogs nearby. But this piece of local knowledge makes some relationship between the eelgrass meadows and the quahogs evident.

On page 3 you say, "It is clear that the importance of eelgrass in Maine waters relative to other types of habitat is totally unknown." Yet Fred Short, whom you cite elsewhere in your letter, said in the report for MDOT titled Distribution of Eelgrass in Penobscot Bay Maine, "The ecological significance of the eelgrass resource to the Penobscot Bay region is great. Its functions and values include fish and waterfowl habitat, tropic food chain basis, water filtration, lobster, shellfish recruitment substrate, and sediment binding and stabilization." The Maine State Planning Office, in The Estuary Book published in January of 1991, reports on page 13 that "Eelgrass plays an essential role in the establishment of shellfish beds and provide nursery areas for many species of fish, shellfish, and crustaceans." The draft Casco Bay Plan (Fall 1995), submitted for public review by The Casco Bay Estuary Project Management Committee, of which you are a part, says, "...eelgrass is considered an indicator of ecosystem health... it is used by flounder, cod, striped bass, scallops, crabs, and lobsters as a nursery area, feeding ground, or refuge from predators."

The January 1983 issue of National Fisherman carried a story by Mike Brown titled Shrimp researchers in Maine discover a finfish nursery, in which he reports that, some 12 to 15 years ago in work funded by DMR, "This data showed conclusively that the upper Penobscot Bay estuary is a gigantic nursery." In fact, according to NOAA eelgrass expert Mark Fonseca in Beaufort, NC, thousands of studies done on eeIgrass worldwide all point to its importance. The definitive piece on eelgrass functions, The Ecology of Eelgrass Meadows of the Atlantic Coast, goes on for more than a hundred pages to describe its importance. Surely that importance doesn't somehow stop at the Maine border!

Maine research by Maine scientists Carter Newell and others has shown that eelgrass beds are associated with virtually all of the large mussels beds in Maine. In the Fall/Winter edition of the Maine Sea Grant publication Nor'easter, author Kathleen Lignell reports that Newell and his fellow researchers "suggest that the first thing managers can do is to make sure eelgrass beds are not disturbed." They summarize their findings by saying, "In the long term, protecting eelgrass habitat... will mean better mussel harvests."

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In the same paragraph on page three you next say, "On the other hand, the importance of mud flats as soft shell clam habitat and marine worm habitat and cobble bottom to juvenile lobsters is well documented." Is this a suggestion that clams, worms, and lobsters are more important than mussels, shrimp, scallops, and numerous finfish? It is my understanding that DMR can not "take a side" in matters pertaining to the comparison of the importance of one resource with another.

Slightly later in the same page 3 paragraph you do quote Short as saying that the number of eelgrass meadows in Pen Bay are small relative to potential and somehow conclude from this that the NMFS statement about the value of eelgrass meadows that would be lost is invalid.

Actually, if Pen Bay has less eelgrass than its potential suggests, this draws us to conclude that the eelgrass meadows we do have are therefore even more important, inch for inch, than they would be otherwise. Eelgrass is a relatively scarce commodity in Pen Bay and we need to conserve and/or develop every inch we can.

Given the abundant scientific evidence world-wide, including research done in Maine, that (1) eelgrass meadows are home to numerous organisms in some stage in their life histories, especially juvenile, (2) eelgrass has a very high rate of primary production (grams weight of plant matter produced per unit area of bottom per day), (3) that the eelgrass canopy provides structure and substrate for refuge and attachment by numerous organisms, and (4) that eelgrass mediates many short-term and long-term biological and chemical interactions within the estuarine system, it certainly seems unusual for you to say in your letter, at the bottom of page four, that, "There is no evidence that this habitat loss will impact mobile finfish" or on page six that "...the role of eelgrass in Maine waters is unknown."

Mr. Fonseca, in a paper he wrote with others titled Seagrass Beds: Nursery for Coastal Species, outlines the value of eelgrass by summarizing thus: "The relative stability of seagrass beds, coupled with their complex structure and high rate of primary production, enable them to form the basis of an abundant and diverse animal community. For many fishery organisms... there are a combination of features which provide many essential resources." He goes on to say that, "...documented declines in seagrass beds have been implicated in reductions of fishery resources."

The Island Institute and others have preliminary evidence that freshwater wetlands located adjacent to and just upland from eelgrass meadows provide a rich source of nutrients for Zostera marina and the organisms that share this marine space. We also know that estuarine systems provide the Gulf of Maine with a nutrient soup that enables phytoplankton to thrive and, in turn, fuel the profusion of marine life still found throughout most of the Gulf. Thus we have this linked web of systems that here-to-fore were considered self-sustaining. Only in recent years have serious declines in various Gulf of Maine organisms occurred due to the negative impacts of our human presence and use.

There is one other issue I take with your assessment of the Evaluation. It strikes me that the importance of biodiversity in an ecosystem is somehow lost in your reading. I believe the Evaluation is pointing to a complex grouping of numerous attributes that, altogether, create an impressive and significant ecological assemblage. I live an an island just two miles south of Sears Island but we do not have nearly the numbers of different species and attributes as were collected in the one 940 acre area on Sears Island. Its proximity to the mainland, while still being an island, as well as its position at the mouth of the river, is truly unique. There are ways to measure this

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and compare biodiversity value with other sites (if sufficient data for both sites is available). One method is called the Jaccard approach; another is known as the Shannon-Weiner index. I do not know specifically how these measures work but I do know that both processes recognize and measure - or at least compare - the value of species diversity.

And that, in the end, may be the central issue here. The SEIS and attendant research makes it perfectly clear to most readers that Sears Island is inhabited and surrounded by a multitude of species. How can we even begin to consider losses to this rich diversity? In exchange for what? Does development of the terminal at Sears Island conserve or develop Maine's marine and estuarine resources? Certainly not. The terminal will permanently eradicate eelgrass meadows, other intertidal and subtidal habitats, as well as freshwater wetlands that feed these marine ecosystems, forever removing the benefits, present and future, provided by these resources and limiting, once more, the marine environment's ability to support commercial levels of finfish, mussels, shrimp, and other organisms.

Robin, we have lost too much of our natural resource base already. Three years ago, when my father died, I had reason to fly over the eastern seaboard from Maine to South Carolina where he had retired. I was amazed to see that the only really extensive expanses of green upland forest and undeveloped coastline were in Maine. We must not lose these greatest of assets. I regret that my first communication directly with you should fall under such adverse circumstances. My only hope is that this letter of yours is some kind of freak and does not really represent your true feelings.

Sincerely,

Stephen Miller
Executive Director

cc.Governor Angus King
Bangor Daily News
Portland Press Herald
Courier Publications
Maine Times
Camden Herald
Islesboro News

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