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Coastal Waters Project
January 29, 1996
Robin Alden, Commissioner
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 water© and sediment©carried 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 ÃÃand on the area likely to be
affected by the proposed development;ÄÄ and
"B. The potential effects on the protection and preservation of
the public's health, safety, and general welfare."
Section 480©D.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 480©E.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 ballastªborne exotic species on the Penobscot Bay ecosystem and related
economic activities.
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Maine Dept of Marine Resources
Marine Resources Laboratory
POB 8
West Boothbay Harbor, Maine 04575©0008