^. 



While there are maziy areas where we are In agreement with the DEIS/MP. we would also 

 liif^ to highlight several concerns of ours where we find the need to suggest additional or 

 alternative options to fully Insure the protection of the resources of the SBNMS. 



BOUNDARIES 



CRU strongly recommends the adoption of Alternative #3 as the boundary for the SBNMS. 2 . See generic response B. 1 . 

 There are several factors that argue In favor of this option. First, with regard to the 

 natural resources themselves, this larger alternative Includes several areas of Importance 

 that the proposed alternative from the DEIS/MP does not 



The eastern side of SteUwagen Bank Is not only often utilized by commercial and 

 recreational fisherman, but our data also demonstrates Its Importance to humpback and 

 finback whales, who use It as a foraging/ feeding ground as well as an avenue for traveling 

 back and forth in this area of the bank, particularly along the 50 and 100 fathom contour 

 lines. Data collected by CETAP (1982) show the 100 fathom line especially Important for 

 right whales. This 100 fathom line Is only Included In Alternative #3. 



The boundary region that extends to the northeast, encompassing Tlllle's Bank. Includes 

 addlQonal waters used heavily by both fishermen and endangered whales. 

 The area to the west of the bank feature Is vital In Its Inclusion of the Massachusetts Bay 

 Dump Site (MBDS). This dumping ground, used over a period of several decades for 

 deposition of a variety of materials including Industrial wastes, dredge spoil, and low level 

 radioactive materials. Is presently being considered for designation as a permanent dump 

 site. Its pro3dmit>- to (or inclusion in) the SBNMS underscores the need for extensive 

 monitoring of the materials to be deposited to eliminate the threat of harm to the 

 resources of the SBNMS. Alternative #3 encompasses the entire MBDS, and would 

 therefore provide additional protection for the SBNMS, 



Management considerations also suggest that alternative #3 would be more suitable for 

 the proposed sanctuary. State ocean sanctuaries would abut the SBiVMS if alternative #3 

 were adopted, and this would provide the opportunity for Joint, comprehensive efforts by 

 local and federal ofEclals. This could be of particular Importance with regard to the 

 Introduction of pollutants Into the SBNMS from land sources. 



In addition, the larger boundary alternative would recognize the dynamics of the 

 ecosystem, specifically that the significant resources of the region, both physical and 

 biological, are not limited to the bank feature itself, nor are the sources of Influence on 

 the bank. We feel the larger area presented by alternative #3 represents the most 

 appropriate boundaries for protection of the "SteUwagen Bank region". 





PROHIBITIONS/REGULATIONS 



CRU Is In support of the following prohibitions as delineated In the DEIS/MP: 



• dredging. excavaUoa or any other alteration of. or construction on. the seabed 

 within the sanctuary. Elxcluded for this prohibition are temporary alterations to 

 the seabed which result from normal fishing operations 



• all aspects of exploration for, or extraction of. Industrial materials (e.g.. sand, 

 gravel, clay) from the SBNMS 



• the removal, alteration, or damage to (or attempt to cause the same) to any 

 historical or cultural resource within the sanctuary 



• the installation of pipelines or submarine cables within the SBNMS (listed in the 

 DEIS, but not in several other areas including pg. 7 of the prospectus). 



"There are several other areas where CRU finds the DEIS/MP either unclear or not 

 protecUve enough of the SBNMS. 



Page G63 



