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Jackson Estuarine Laboratory
University of New Hampshire
85 Adams Point Road
Durham, NH 03824
Phone (603) 862-2175 FAX (603) 862-1101

Robin Alden, Commissioner
Department of Marine Resources
Marine Resources laboratory
PO Box 8
West Boothbay Harbor, Maine 94575

30 November 1995

Dear Robin Alden:

I have been given a copy of a recent letter (October 13, 1995) which you wrote to Mr. Paul Lariviere and Lt. Col. Michael Bradbury in defense of the Sears Island Dry Cargo Terminal in Searsport, Maine, in which you went to some length to discredit the importance of eelgrass habitat in Maine, based largely on a Draft Report prepared by G. S. Wippelhauser in the Spring of 1995 (Eelgrass in the Gulf of Maine: ecology and management. Draft ms. prepared for the Maine Coastal Program, Maine Natural Areas Program, Maine Department of Conservation.).

The foundations of this Draft Report are extremely weak and the report has received very critical reviews that directly contradict many of the premises it sets forth. I enclose a copy of my review of Wippelhauser's Draft Report, which was sent to the author on July 26, 1995. I have heard that other knowledgeable scientists, Dr. Phil Colarusso of the EPA among them, have submitted equally critical reviews of this report. I feel it is fundamentally irresponsible to base critical decisions regarding the ecology of the Gulf of Maine on a Draft Report that presents false and misleading information. I am distressed to see this document being used and circulated as creditable, when it is not.

I write to you as a research professor at the University of New Hampshire, Department of Natural Resources. I have spent 20 years working on various aspects of seagrass ecology, the past 12 working in New England, including extensive work in Maine. As you know, I worked for the State of Maine as a consultant on the Sears Island Supplemental EIS, conducting the eelgrass surveys, mapping eelgrass in Penobscot Bay and identifying mitigation options. I do not believe that environmental protection must exclude economic development. Rather I feel that habitat functions and values impacted by the development process must be acknowledged and compensated for.

The Wippelhauser Draft Report does not represent an accurate review of the status of eelgrass in Maine. As you will see from my enclosed review there is a lot of information known about eelgrass and its values; this habitat is far from being "totally unknown", as you say in your letter. Such information was made clear to Dr. Wippelhauser by myself and others at a workshop on May 23, 1995. The importance of eelgrass habitats in Maine was also clearly summarized in a 1995 report to the Gulf of Maine Monitoring Committee on Strategies for Further Implementing

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the Initial Plan prepared for the Maine Office of State Planning by Dr. D. D. Turgeon of NOAA.

Additionally, your Department has recently begun documenting the distribution of eelgrass in Maine, finding far more extensive eelgrass habitat in Maine than previously thought. Although there has not been as much investigation of eelgrass habitat in Maine as elsewhere in the U.S., there is certainly enough information to show that eelgrass is an important and valuable habitat. If you would like further information please feel free to contact me.

Additionally, your letter of October 13th quotes my work out of context in an a way that attempts to make my statements appear contradictory. It is not contradictory to say that eelgrass is widespread and extremely important and also that eelgrass area is small relative to the entire bay. This is actually the predominant situation in all coastal environments. Ecological importance does not directly correlate to the area of a habitat. Generating this kind of misinformation does not serve the Maine Department of Marine Resources well.

My concern is that the ecology and ultimately the fisheries of Maine will be threatened by the loss of coastal habitat and such loss begins with the lack of acknowledgment of resource values. I am writing to you because I believe an important ecological resource is at risk, and I want to see the law of the State of Maine and the actions of its departments reflect the best scientific knowledge available for sustaining the marine environments of the Gulf of Maine.

Sincerely,

Frederick T. Short, Ph. D
Associate Research Professor
Natural Resource Department.

cc:

Governor Angus King, Jr Governor of the State of Maine
Dr. John DeVillars, regional Administrator, US Environmental Protection Agency
Mr. John Melrose,Commissioner, Maine Department of Transportation
Mr. Paul Lariviere, Division Administrator, Federal Highway Administrator
Lt Col Michael Bradbury, District Engineer, US Army Corps of Engineers.
Dr. Paul Colarusso, US. Environmental Protection Agency
Mr. Brian Nutter, Maine Department of Transportation
Ms. Josie Quintrell, Maine Office of State Planning
Dr. Gail Wippelhauser, Maine Natural Areas Program.

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