Be are concerned that if NOAA eventually decides to either 

 regulate traffic patterns or enforce vessel speed limits, soae of the 

 ocean comaon carriers currently calling Boston might discontinue 

 service to the Port. To the steamship lines, -staying on schedule' is 

 more than a sales pitch, it ■ s an obsession - and they never hesitate 

 to sacrifice port rotation or to omit small ports of call (like 

 Boston) for the sake of schedule integrity. Also, ocean carrier 

 principals, especially foreign-flag ones, are strangely sensitive 

 about drawing civil penalties. Vhile initially they may either pay the 

 fine or go through the appeals process like anyone else, their 

 ultimate response to the problem is to avoid such future 

 unpleasantness by keeping as far away as possible from areas of 

 potential confrontation - unless thev absolute ly have no other 

 options. Should NOAA elect, at some future point in time, to actually 

 try regulating commercial vessel traffic in the Stellwagen Bank area. 

 we strongly urge that such determination not be made without prior 

 notification of the proposed action in a public record and proper 

 invitation for public comment. If this decision is ever made in 

 isolation. NOAA will have to shoulder the responsibility for 

 potentially exporting Boston' s waterfront jobs to such rival ports as 



u 



New York and Montreal, and for helping those ports to become New 

 England's commercial gateways to the world. 



DREDCED MATERIAL DISPOSAL : Boston Harbor has been under 

 improvement by the Federal Government since its adoption of the 

 original project in 1825. The existing project was authorized by the 

 River and Harbor Act of 1867, which has since been supplemented by 

 numerous congressional authorizations. The most recent authorization, 

 enacted on October 23. 1962. provides for channels ranging in depth 

 from 27 to 40 feet, and for the 40 foot deep President Roads anchorage. 



The 1962 project has been inadequate probably since 1975. In the 

 early sixties, the average ship calling at Boston measured anywhere 

 from 530 to 600 feet in length. Army Corps of Engineers statistics 

 show that only 21 of the total 1962 ship arrivals entered the harbor 

 drawing more than 35 feet of water. All other vessels visiting Boston 

 that year recorded 27 to 32 foot drafts. In contrast some of the 

 container vessels, liquefied natural gas (LNG) ships, and oil tankers 

 calling Boston in 1991 are well over 900 feet in length and sometimes 

 draw as much as 41 feet. 



Today, when such deep draft vessels come to Boston, they are 

 usually forced to transit the harbor area during periods of high 

 water, and often only in daylight hours. The limited depth available 

 in the 35 foot tributary channels results in tidal delays, giving rise 

 to more costly operations, such as lightering at anchorage, light 

 loading, and use of smaller ships. Berthing delays awaiting favorable 

 tidal conditions are expensive, and have no doubt contributed to the 

 decision some steamship accounts made years ago. to curtail or 

 downright abandon service to the Port of Boston. Foremost among our 

 losses which can be attributed, at least in part, to inadequate 

 channel depths are certain specialized bulk carriers, whose lumber 

 cargoes originated out of Western Canada. 



Fortunately, in September 1988, following the completion of a 

 fifteen-year-long feasibility study, the U.S. Army Corps of Engineers' 

 Board of Engineers for Rivers and Harbors (BERH) favorably recommended 

 deep-draft channel improvements for the Port of Boston which are more 

 in line with the navigational realities of the nineties. 



The proposed Boston Harbor improvement plan calls for the 

 deepening of the existing 1962 federal navigation project from the 

 current 35 feet to 40 feet in the Mystic River and Reserved Channel; 

 and from 35 feet to 38 feet in the Chelsea River. The project also 

 includes enlarging and deepening the confluence area at the mouth of 

 the Chelsea and Mystic Rivers, and widening the entrance of the 

 Reserved Channel. Some 2.400.000 cubic yards of ordinary harbor bottom 

 material will require removal and proper disposal. 



3. See generic response F. 



The current forecast schedule shows the project's 

 preconstruction. engineering and design (PED) phase (which began in 

 September 1990) as taking approximately three years, followed by a 

 two-year actual construction period. The cost of the entire 

 undertaking is presently estimated at $31. 3 million. Once completed. 

 the proposed improvements will not only reduce the aforementioned 

 tidal delays, but also promote harbor safety, and produce greater 

 navigational efficiencies. 



Page GllO 



