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Our preferred option, boundary #3, would not necessitate the 

 moving of the MBDS, because both the MBDS and the IWS are 

 located within this boundary. This would allow monitoring 

 of the IWS and make future remedial action possible. It 

 would also provide the Sanctuary manager with a voice 

 concerning the type, quantity and quality of material to be 

 disposed of at the MBDS, a feature which we consider to be 

 beneficial and extremely important. 



2) The Massachusetts Bay Disposal Site. The relationship 

 between the MBDS and the Sanctuary is difficult and 

 problematic. As stated above, we believe that the MBDS 

 should be located within the boundary of the Stellwagen Bank 

 National Marine Sanctuary. This would allow the Sanctuary 

 manager and staff to monitor the type, quantity and quality 

 of the disposal material. At a minimum, any materials 

 disposed of at the MBDS (wether its location is within or 

 outside of Sanctuary boundaries) should meet the most recent 

 and stringent EPA ocean dumping guidelines. Proper 

 monitoring procedures, as determined by the Sanctuary 

 manager and advisory committee should be inplemented to 

 insure that such activities do not harm Sanctuary resources. 

 If the MBDS is located outside of the Sanctuary, the 

 Sanctuary manager should be involved in all decisions 

 pertaining to the use of the site. 



3) The operation of recreational vessels in Sanctuary 

 waters. We recommend that recreational vessels operating 



in Sanctuary waters be subject to regulation. Data 

 collected by the Center for Coastal Studies strongly 

 suggests that increasing numbers of right, humpback and fin 

 whales are being struck by recreational vessels and that 

 these vessels can and do pose a risk to the well being of 

 these endangered species. Regulations pertaining to maximum 

 speed (we suggest an 18 knot maximum) and high speed, 

 "jackrabbit" starts would add important protection to marine 

 mammals and reptiles in Sanctuary waters. It would also 

 safeguard human users of the Sanctuary. 



"4) Offshore hydrocarbon activities. We would also strongly 

 encourage NCAA to prohibit offshore hydrocarbon activities 

 within the sanctuary and that the process of transferring 

 hydrocarbon products from one ship to another (lightering) 

 be prohibited. These activities can have only negative 

 impacts on sanctuary resources and are not consistent with 

 needed protection. 



5) Aquaculture activities. The IWC and its membership 

 believe that aquaculture is not an activity compatible with 

 sanctuary designation. Aquaculture activities not only 

 threaten marine mammals, seabirds and marine reptiles with 

 entanglement, but also represent an exclusive use of 

 Sanctuary resources which would significantly impact 

 traditional forms of commercial fishing. Aquaculture 

 containment structures also represent a significant hazard 

 to navigation. 



6) The removal of sunken vessels. He recommend that the 

 section requiring boat owners to be responsible for the 

 removal of sunken vessels be amended to state that boat 

 owners convicted of willfully disposing of their vessels in 

 Sanctuary waters be responsible for the removal of such 

 vessels. 



4. See generic response K.l. 



5. See generic response E. 



6. See generic response G. 



7. Proposed Sanctuary regulations do not 

 specifically require vessel owners to 

 assume responsibility for the removal of 

 such vessels which sink within the 

 Sanctuary. 



^. 



7) Sanctuary Advisory Committee. We recommend that the 

 Sanctuary management plan include the formation of an 

 advisory committee. This committee will act to provide the 

 Sanctuary manager with information and insight to be used in 

 the decision making process 



8) Staffing and program support. The International Wildlife 

 Coalition supports full and immediate staffing of the 

 Stellwagen Bank Marine Sanctuary office. We believe that 

 such staffing should include a Sanctuary manager, research 

 director, education director and enforcement personnel. The 

 effective operation of this staff will directly depend upon 

 the financial support provided to the Sanctuary. We support 

 maximum funding for enforcement, education, research and 

 monitoring programs. Ke suggest a primary site be located 

 in the town of Plymouth, Massachusetts because of its 

 central location in relation to the Sanctuary and 

 neighboring population centers, established reputation as a 

 tourism center with whale watching and a whale museum and 

 the availability of inexpensive on or near water 



of fice\visitor facilities. Ke also support the creation of 

 "satellite" information centers in the towns of Gloucester 

 and Provincetown. 



8. See generic response O. 



9. It is NOAA's intention that the 

 Sanctuary be fully funded at the time of 

 designation. At the time of final desig- 

 nation, NOAA intends that a Sanctuary 

 Manager will have been hired, and that a 

 Sanctuary headquarters facility will be 

 located in Plymouth, MA. 



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