i 



An adequate monitoring program should be implementet^ to deect any adverse 

 impacts on san^a.7 resources or qualities. In addition, it should be clearly stated, 

 tot^ mat er if 7c MBDS be in sanctuary boundaries or outs.de the burden of 

 nroof^U blon the discharger to show that sanctuary resources w,U not be damaged 

 SXre a peLt/certification'can be given. In th.s regard, the sonctuon. program 

 should pay special attention to the potential for cumulauve unpacts. 



NOAA should be required to officially "approve" or "disapprove" a permit or 

 certification request. The requirement will allow NOAA to achieve its goa^ of 

 prmertng "he resources so as to avoid creating a situation where an actmty ma^t be 

 ^ r^^el because "no action" was taken by the ag-^^ This -'^ ^^^^^^ "^^'^ 

 bi the Memorandum of Agreement between NOAA. EPA and COE. The sanctuary 

 monageVand the sanctuaiyadvisory committee should be very aa.ve m these 

 decisions. 



The sanctuary program should be used as a vehicle to improve and moriitor 

 water qu^iw^n thVaVea. We look to NOAA to work with existmg water quality 

 ma^lemem entities to ensure that established water quality standards for already 

 "e^^ted point source discharges are fiercely enforced -f^ -° -"°-J--"'='^- ^" 

 addition, NOAA should vigorously pursue and encourage the best avmlable 

 mi^a°emenVand monitoring practices to minimize pollution associated ««h land 

 STedi^urces including effluent outfall tunnels. We are especially concerned with 

 Sr Massachusetts Water Resources Authority (^"^^^'Z^lT ' 



- which will spew out 500 million gallons of pnmary treated effluent mio 

 Massachusetts Bav daily for at least four years - will have on the resources. Tliere is 

 s^a ^^at^oncL ailong many scientist of the impacts this amount of increased 

 nutrients will have on this fragile ecosystem. 



Vessel Traffic - CMC is in support of NOAA's recommendation to place commerda] 

 Sh^the scope_ofreg^Lo._and to research tins a^^^^ We 



s 



c 



I 



tramc unaer ine scope ui icgumuuiL^ .^- ~ ' " , . „ .„, lu, ,._„, ^c 

 also recommend that recreational vessel traffic be placed "^.'l" .'^^^^^"P' °' _ . by 

 regulations and researched immediately. Suffiaent informanon has been coUerted by 

 orSn^rLluding the Center for Coastal Studies, New Englaijd Aquanum, arid 

 C?^ Research Unit indicating that most vessel strikes on *bales n^y becat^ed 

 bv relatively small boats. The DEIS/MP also pomts out on page 74 that 60% of the 

 200 whales in the New England Aquarium's photographic catalog exhibit markings 

 presumed to be charaaeristics of vessel collisions. 



' The DEIS/MP states (page 70) that future shipping in the area will "be 



dominated bv the movement of petroleum". However it also reports thatlhe 

 ■possibility of oil spills resulting from vessel collisions is very mimmal. |he Center 

 disputes Uiis statetiient especially because Boston is one of the top ten U.S. ports m 

 the quantity of oa it handles. The Center would like to see NOAA discuss 

 probabilities of oil spills for the area in the FEIS/MP. TTiis mformation can be 

 avanable from the Coast Guard, NOAA's Ocean and Manne Assessment^d 

 Minerals Management Service. Events including oil spills that ocoirred off the coasts 

 of Alaska, Rhode Island. Delaware, and Texas, the last three occurring dunng a single 

 dav in June 1989 demonstrate that accidents do occur and can result m extensive 

 d^age to marine resources. The Center recommends that NOAA support efforts to 

 monitor the movement of commercial cargo vessels in the area to alleviate vessel 

 collisions and other events that may lead to oil spUls. A suggestion is to develop a 

 Vessel Traffic System for the area. 



Off^hor. r... ,M Oil Development: The DEIS/>^ states on page 96 that "the 



?. 



hghest management priority for the proposed sanctuary is long-term protection of the 

 S and non-Uving Resources of the Stellwagen Bank system." 1° *-^"g '°*^^„ 

 this goal, CMC recommends that NOAA permanently prohibit offshore hydrocarbon 

 activities within the boundaries of the sanctuary. We strongly disagree with NOAAs 

 stated approach to only list this activity within the scope of r^g^l^t^- ^1= 

 moratorium on the development of hydrocarbons unul the year 2000 for the ^ 

 Stellwaoen Bank area does not provide the long-term protection that the areas 

 resources deserve especially as a national marine sanctuary. NOAA recogmzes on 

 pace 169 the dangers of gas and oH development. It also recogmzes on the same 

 paie that "the biological resources of the Stellwagen Bank system, "P^'^^J ^J; 

 m^e mammals and the commercially-important fishenes. will always be vulnerable 

 to the effects of oil and gas development activities". A prohibition on oil and gas 

 activities within the Sanctuary's boundaries would provide peirnanent protection to 

 these and other resources. This prohibition would not be a duplicauon of the 

 moratorium since a prohibition wnll provide long-term protection for the resources. 

 This prohibition is consistent with NOAAs goal; to protect the areas resources. 



AfluaoillUK: Aquaculmre facilities are a navigational hazard, increase the 

 potentiffC^eXunal entanglements and o»«tn.««dmona^^ us«o Je 

 indudine commercial fishing. This activity is not compatible with protectmg me 

 Snt^feSr« CMC urges NOAA to prohibit aquaculmre activines in the 

 sanctuary. 



Bank 



4. See generic response C.2. 



5. See expanded discussion at PART 

 THREE, Section II.C.ll. and 12. See 

 also generic response K. 



6. Given the safety record of commercial 

 shipping operations within the Vessel 

 Traffic Separation Scheme in and out of 

 Boston, NOAA has not found coinpelling 

 reasons at this point to develop 

 detailed discussions on the 

 probabilities of an oil spill within the 

 Stellwagen Bank area. However, 

 development of the Sanctuary's 

 contingency plan will address these 

 areas of investigation. 



7. See generic response E. 



8. See generic response G. 



Page G59 



