1. 



Boundary Alternatives: 



Along with the Stellwagen Bank Coalition, the Center for Coastal Studies 

 recoiMends that Boundary Alternative S3 be chosen as the final boundary for 

 the designated sanctuary. khile NOAA's preferred Alternative il complies to 

 aooie degree with the DEIS' stated goal of encompassing identified important 

 marine habitats related to cyclic upwelling, marine mammal and seabird 

 feeding habitats, spawning areas for sand lance, and vital commercial 

 fisheries resources (page 129), we feel that far more effective protection 

 could be undertaken with the larger boundary. Expansion of the boundary to 

 Alternative #3 would allow for protection of the fisheries resources on 

 Tillie's Bank and on southern Jeffrey's Ledge. The latter area is also an 

 important seasonal feeding ground for the harbor porpoise, Phocoena 

 phocoena . currently under consideration by the National Marine Fisheries 

 Service for listing as a depleted population under the Marine Maamal 

 Protection Act or as a threatened or endangered species under the Endangered 

 Species Act (Fed. Reg, 2/13/91). 



Title Ill's directive that the purposes and policies of National Marine 

 Sanctuaries are "to provide authority for comprehensive and coordinated 

 conservation and management of these marine areas that will cooplement 

 existing regulatory authorities" [Sec. 301 (b) ( 2 ) ] can be best net by 

 Alternative #3. If designated with boundaries established under Alternative 

 -3, the Sanctuary will abut the North Shore, South Essex and Cape Cod State 

 Ocean Sanctuaries, thus best establishing the potential for cooperative 

 federal and state ocean management. The National Marine Sanctuary Program 

 Regulations (15 CFR 922) recommend that sanctuaries can assist in the 

 formation of "a management umbrella over a fragmented system to help 

 coordinate and strengthen diverse, but related efforts." We feel that only 

 Alternative #3 adequately fulfills this approach. In fact, NO.A.A clearly 

 recognizes that "Adoption of Boundary Alternative #3 would also establish 

 the potential for Marine Sanctuary and Commonwealth cooperative ocean 

 management planning through the Massachusetts Ocean Sanctuary Program and 

 the Massachusetts Bays Program." (page 131). 



He do not feel that the larger sanctuary size of 702 square nautical miles 

 encompassed by Alternative #3 should present additional difficulty in 

 enforcement or management, particularly in light of the fact that NOAA 



currently nanages two other earine sanctuaries of con3iderabiy larger size: 

 the Channel Islands (1252 square nautical ailes), and the Gulf of the 

 Faxallones (948 square nautical ailes), and has recently designated the 

 Florida Keys National Marine Sanctuary, which will cover 2600 square 

 nautical ailes. 



The inclusion of the Massachusetts Bay Disposal Site (MBDS) within the 

 sanctuary boundaries, as defined in Alternative #3, will allow for 

 cooperative oversight of the MBDS by NOAA. Future management of the MBDS, 

 and the potential for disposal of contaminated aaterial at the site, is a 

 major cause of concern for all the aembers of the Stellwagen Bank Coalition, 

 auch of the fishing coamunity, and the general public (see below). 



CENTER FOR COASTAL STUDIES 

 1. See generic response B.l. 



»2. 



Maoageaent Alternatives: 



The Center for Coastal Studies supports Manageaent Alternative «3 . which 

 would establish a central Sanctuary headquarters within six nonths after 

 designation. This headquarters should be fully staffed with a Sanctuary 

 Manager, research coordinator, education coordinator, two enforceaent 

 officers, and a clerical assistant. In addition, we suggest that NOAA 

 consider locating this office in a central location with good visitation 

 potential, i.e. Plyaouth. 



We also feel that satellite offices should be established as quickly as 

 possible, preferably within the first year after designation. The 

 Stellwagen Bank National Marine Sanctuary, if designated with Boundary 

 Alternative J3, would stretch froo the Massachusetts Bay North Shore to the 

 tip of Cape Cod - a linear distance of approxiaately 40 ailes. Satellite 

 offices in Gloucester and in Provincetown would be particularly effective in 

 adding the aaxiaua possible exposure for the Sanctuary prograa, since 

 Provincetown and Gloucester are currrently the two largest centers of 

 coamercial whalewatching and recreational boating to the Stellwagen Bank 

 area. Provincetown also receives the treaendous added tourisa component of 

 the Cape Cod National Seashore, the Bost visited National Park in the United 

 States. 



Any educational or public relations prograas at a centrally-located 

 headquarters office (for exaople, on Boston's South Shore) would be likely 

 to aiss this huge user group. A single staff person, focusing on 

 educational outreach, in each of these two satellite areas, would greatly 

 increase Sanctuary visibility. 



In addition, recreational fishing targeted at the blue-fin tuna aarket is 

 generally concentrated on Stellwagen's northwest and southwest corners; aany 

 of the boaters involved in this fishery use Provincetown and Gloucester as 

 seasonal hoae ports. Boater education prograas regarding Sanctuary 

 regulations are likely to be best served through Sanctuary personnel located 

 in these two ports. 



NOAA's justifies its preferred Manageaent Alternative 12 based on its being 

 the aost cost-effective alternative (page 133). However, we believe that 

 two satellite offices, aaintalned with one representative each, could be 

 established for an additional $85,000 in rY1992, a relatively saall cost 

 considering the potential benefits. This proposed additional budget is 



2. Comments noted. See PART THREE, 

 Section II. B. 



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