3. 



5 



C. 



The Massachusetts Bay Disposal Site (MBDS) lies within 

 Alternative # 3's boundary lines. The threats posed by prior 

 disposal activities and future projects nnjst seriously be examined 

 by leading federal and state environmental agencies. Efforts must 

 be made to ensure that Stellwagen Bank's ecological integrity is 

 protected from adverse activities not only from within the 

 sanctuary boundaries but also from outside sources. Therefore by 

 including the MBDS as proposed in Alternative 3, there will be a 

 guarantee of greater awareness and careful screening for future 

 disposal efforts. MBDS's close proximity to the banJc may 

 ultimately pose significant threats to the health of Stellwagen 

 Bank's biological communities. Only, uncontaminated and 

 biologically non-threatening material should be considered for 

 disposal at the MBDS. An adequate monitoring program should be 

 developed to monitor post-disposal effects. 



Vessel traffic - Efforts must be considered which will 

 monitor the effects of vessel traffic throughout the sanctuary. Of 

 greater concern is the risk of accidental collisions or vessel 

 emergencies which may ultimately pose threats to Stellwagen Bank. 

 Legislative initiatives have been adopted within other states (i.e. 

 Alaska and Rhode Island) to expand a satellite monitoring system 

 (e g. Global Positioning System). The programs are designee to 

 track commercial vessels transporting hazardous cargoes, thereby 

 preventing possible vessel collisions or groundings. NOAA should 

 examine and consider these programs in an effort to protect 

 Stellwagen Bank and the other marine sanctuary sites. 



To protect the sanctuary a contingency plan needs to be 

 included in the EIS/MP to address vessel emergencies (e.g. oil 

 spills). The contingency plan should provide a framework and 

 guidelines for a quick and effective response. 



Hydrocarbon exploration, drilling and transfer - Stellwagen 

 Bank lies within the North Atlantic Planning Area of the Atlantic 

 OCS Region. Leases for exploration have been considered for this 

 region. Even though a Presidential order canceling the lease sales 

 has been in place since June 1990, Massachusetts Audubon recommends 

 that the EIS/MP include a prohibition of any activity which will 

 increase the probability of hydrocarbon contamination. Therefore, 

 all hydrocarbon exploration, drilling or fuel transfer (i.e. 

 lightering) should be prohibited within the sanctuary. 



Ocean Waste Incineration and Diacbarge - There is significant 

 evidence available to show that ocean incineration and discharge of 

 wastewater/sludge pose significant threats to marine systems. 

 Massachusetts Audubon strongly recommends that all waste discharges 

 and incineration ventures be prohibited within the sanctuary. In 

 addition, research must be expanded to evaluate and monitor the 

 cumulative impacts of current and future wastewater discharges and 

 their long term impact on Stellwagen Bank. As reported in the 

 DEIS/MP, steps are being taken by Massachusetts communities to 

 lengthen wastewater outfalls and increase discharge volumes to 

 Massachusetts bays (e.g. Gloucester, South Essex Sewer District, 

 Plymouth and MWRA) . These along with future proposals must be 

 carefully examined in a comprehensive manner. 



Management Alternative - Massachusetts Audubon strongly favors 

 management alternative # 3 as a method for implementing the 

 sanctuary management plan. The implementation of an effective 

 public information program will enhance the EIS/MP goals and 

 objectives, in addition to establishing a strong constituency who 

 will work to support the long term efforts of the Marine Sanctuary 

 program. The 'satellite center' concept is an ideal method for 

 disseminating sanctuary information to the public. 



Massachusetts Audubon strongly supports NOAA efforts to 

 provide the necessary protection to insure that Stellwagen Bank's 

 ecological integrity is preserved for the future. We appreciate 

 the opportunity to respond and we hope that the Society's comments 

 and recommendations are useful in completing the final EIS/MP. 

 Thank you for your careful consideration. 



3. See generic response K.2. 



4. See discussion at PART TWO, Section 

 III.B.3. The Sanctuary contingency plan 

 will address the issues of emergency 

 preparedness, including installation of 

 necessary equipment at appropriate 

 locations. Additionally, the Sanctuary 

 contingency plan will be coordinated 

 with the existing National Contingency 

 Plan, to further ensure mechanisms for 

 quick and effective response to 

 emergency situations. 



5. See generic response E. 



6. See generic response H. 



7. Comments noted. See PART THREE, 

 Section II. B. NOAA intends that a 

 Sanctuary Manager and office facility 

 will have been selected by the time of 

 final designation. Remaining Sanctuary 

 staff should be hired shortly 

 thereafter. 



Sincerely, 



jerard A. Bertrand 

 President 



Page G74 



