The NEAq reconunends that NOAA engage In a dialogue with the Stellwagen Bank 

 Coalition and commercial fishermen, to develop an educational program specincally 

 for the commercial fisheries using the sanctuary. This program xould seek to help 

 fishermen understand how the sanctuary will benefit them, what sanctuary regula- 

 tions apply to them, and how they can play a role In Improving the management and 

 research programs of the sanctuary. It Is important that all users of the sanctuary 

 feel a sense of ownership of the sanctuary. Only through such personal connection 

 to the resources of our oceans can the process of stewardship be engaged. 



s. 



(.. 



Bffsearch Program 



* Ipp 14-15- pp. 106-81 One of the stated goals of the research program Is to 

 facilitate 'mpr'oved management. Nearly every attempt at protecting and managing 

 resources has suffered from an inadequate attention to the importance of cumulative 

 Impacts of multiple environmental threats. 



The DEIS MP is correct in stating that the research program should identify the range 

 of effects on the sanctuary resulting from human activities. Hoxever. we strongly 

 f»-l that the DEIS/MP should e.Tpllcitly state that a major goal of the research 

 program is to determine the synergistic effects and cumulative impacts of human 

 activities and to aid in the development of decision making tools that fully consider 

 these combined effects. The Sanctuary Research Plan should be developed with an 

 emphasis on the assessment of synergistic effects and combined impacts, and research 

 priorities should be built upon this foundation. 



Education 



♦ Ip 151 The primary goal of the Interpretation/education program is to Increase 

 public awareness of the significance of Stellwagen Bank and the need to protect It 

 It IS our belief that this goal cannot be fully realized without the full staffing and 

 funding provided by Management Alternative 3. Furthermore, we feel that it Is vital 

 that the sanctuary headquarters and satellite offices not be obscured by absorption 

 into other federal or state programs/sites. For example, a satellite office at the 

 Cape Cod .National Seashore office may be appropriate, but the program should stand 

 alone, and be well advertised as a separate entity with its own staff. 



Enforcement 



5. Following designation, annual 

 Sanctuary research plans will be 

 developed. Included in such plans will 

 be those research topics which focus o 

 short- and long-term management of the 

 Sanctuary, and on targeted areas for 

 which the Sanctuary requires additiona 

 data and understanding. Within this 

 context, research projects addressing 

 the cumulative effects of human 

 activities on Sanctuary resources will 

 be considered. 



6. At the time of Sanctuary designation 

 NOAA intends that a Sanctuary Manager 

 will have been hired, and that a 

 Sanctuary headquarters will have been 

 identified. NOAA has selected Plymouth 

 as the location of the Sanctuary 

 headquarters facility. NOAA intends tha 

 the Sanctuary Program be independently 

 identified and housed. 



, , ,, , 7. NOAA recognizes the importance of 



♦ Sanctuary regulations will have little effect without the beiiefit of full-Ume enforcement personnel for the Sanctuary 



enforcement staff, as would be provided through Management Alternative 3. Although ="^°f'^^"^'' X^^^ „„_j. ^^aff be hired 



coordinated efforts with the Coast Guard will be Important, such activities do not and intends that such Stat t t)e hirea 



eliminate the need for funded enforcement officers, 

 sanctuary fails, the sanctuary will fall. 



If the enforcement aspect of the 



soon after the identification of the 

 Sanctuary Manager. 



/O. 



/I. 



Management Issues & Alternatives 



♦ [p. 861 The DEIS/MP clearly states that at-sea incineration operations threaten 

 to the resources of the sanctuary, and that this activity should be regulated; yet. no 

 regulation/prohibition of such activities Is proposed. We recommend that at-sea 

 incineration activities be prohibited within the sanctuary. 



♦ (p. 1021 The DEIS/MP rightly prohibits alteration of the seabed, except "tempo- 

 rary" alterations resulting from "normal" fishing operations. However, "temporary" 

 and "normal" must both be explicitly defined. Such definition Is crucial in light of 

 the proposals to begin a Stlmpson Clam dredging operation on Stellwagen Bank Ip. 

 631. These types of operations may be extremely damaging to the fragile ecosystems 

 on and around Stellwagen Bank. If so, they should be prohibited. 



"♦ Ipp. 147-81 The NEAq recommends that exploration for. and development of.- 

 hydrocarbon reserves be prohibited within the sanctuary. Such activities are 

 Inconsistent with the prohibition of permanent alteration to the seabed, as they 

 necessitate both construction on. and drilling Into the sea floor. More Importantly, 

 these activities are an Inherent threat to the long-term health of the Stellwagen 

 Bank ecosystem. Primary producers (plankton) and fish larvae would be placed at 

 serious risk by both "normal" operations and accidental spills. Other animals within 

 the food web would also be adversely affected. 



The DEIS/MP cites the present moratorium on hydrocarbon development In the 

 Northeast as Justification for avoiding an outright prohibition of such activities with 

 the sanctuary. However, as Is evidenced by recent attempts to open the Arctic 

 National Wildlife Refuge to oil and gas exploration, moratoriums are vulnerable to 

 shifting political winds. The existence of a moratorium on these activities does not 

 ensure that they will not be allowed within the sanctuary. Increased demand on 

 domestic oil reserves, or unforseen changes In the world market could suddenly spur 

 a rush to explore for hydrocarbons In the Northeast. 



"♦ Another Issue of concern Is the ship-to-ship transport of hydrocarbon products. 

 Such operations occur with regularity In Massachusetts Bay. as many deep water 

 tankers must lighten their loads before entering the relatively shallow waters of 

 Boston Harbor. Anecdotal evidence suggests that "minor" spills occur frequently 

 during the off-loading of oil and gas. These operations pose significant risk of 

 larger spills, especially during rough seas. Having considered the risks presented by 

 such activities, the NEAq recommends that they be prohibited within the sanctuary. 



8. See generic response H. 



9. NOAA does not agree that the term 

 "temporary" requires definition, as it 

 is used in the proposed prohibition on 

 alteration of the seabed. The term 

 "normal fishing operations" has been 

 changed to "traditional fishing 

 operations", where appropriate. See 

 also generic response N. 



10. See generic response E. 



11. See generic response F. 



Page G79 



