L 



7. 



^. 



■ As currently listed under prohibited activities, § 940.S (1) iii, bilge pumping would 

 not be allowed. We have been informed that there is now an awareness within the 



Sanctuaries and Reserves DivUion of the potential problems with this provision. 

 The Coundl recommends deletion of the section since prohibitions on discnargmg 

 from vessels already exist under MARPOL. 



With regard to other dumping activides, the Council supports prohibitions on 

 ocean dumping (except as allowed within the Mass Bay Disposal Site and 

 accomplished with Sanctuary approval), sewer outfalls and other discharges that 

 adverseW affect fisheries habitaB and resources within the sanctuary. Vessds may be 

 Sated with respect to discharges or deposits within the sanctuary, but the Council 

 has endorsed specific vessel exemptions contained in other sanctuary management 

 plans; those plans referenced "fish, fish parts or chumming materials, water 

 Cding cooling water), and other biodegradable effluents madental to vessel use 

 in the sanctuary generated by marine sanitation devices; routine vessel maintenance; 

 engine exhaust or meals on board"; 



' As stated in earlier comments to your office, we support the prohibiHons as 

 proposed on sand, gravel and mineral mining, pipelines and cables, fb<ed or floatmg 

 Ltforms and alteration or construction of the seabed -^^^ ^' ''f'^^J^' 

 Lther recommend that additional prohibitions be added '° '^■^ ^^^ '^y'^^^^^" 

 (oil and gas) exploration, development and production, bghtermg (transfer of 

 hydrocarbon products from ship to ship) and at-sea incineration of waste materials. 



- The Council favors Management Alternative #3 which provides for an on-site 

 Sanctuary Manager, research coordinator, education coordinator and one or inore 

 enforcement officials. Enforcement officials, as the Council tus P^«^.'°"^^^^'^'5f:^„ 

 should be properly selected, trained, equipped and capable of enforcing bodif^henes 

 laws and sancmary regulations. SimU.'ly, education programs should mclude 

 information about traditional and current fisheries activities (both commercial and 

 recreational). We recommend that fisheries research activities as <^ed out oy the 

 research coordinator, be reviewed and coordinated with the New England Counal, 

 as well as other State and Federal agencies. 



The Council appreciates the efforts of the Sanctuaries and Reserves Division to 

 reco<nii2e the important historic and economic uses of Stellwagen Bark to the 

 fishing community and to ensure the participation of the Regional Fishery Counals. 

 We will continue to provide input as the designation process contmues. 



Sincerely, 



Robert A. Jones[&i^ 

 Chairman 



Stellwagen Bank Coalition 

 c/o Center for Marine Conservation 

 1725 DeSales Street. hW 

 Washington, DC 2(X)36 



April 9, 1991 



Joseph A. Uravitch, Chief 



Sanctuaries and Reserves Division 



Office of Ocean and Coastal Resource Management 



National Ocean Service/NOAA 



1825 Connecticut Avenue, N.W, Suite 714 



Washington, D.C 20235 



Comments on Draft Environmental Impact Statement/Draft Management PIm 

 (DEIS/MP), February 1991) and Proposed Regulations (Federal Register. Volurne 58. 

 No. 27. February 8, 1991. pages 5282-5295). Proposed Stellwagen Bank National Manne 

 Sanctuary. 



See generic response C.l. 



7. See proposed Sanctuary regulation at 

 15 CFR § 940.5(a) . 



8. See generic responses E. , P., and H. 



9. At the time of final Sanctuary desig- 

 nation, NOAA intends to have hired a 

 Sanctuary Manager and to have identified 

 a Sanctuary headquarters. Within a short 

 time thereafter, NOAA anticipates the 

 hiring of additional Sanctuary staff, 

 including a research coordinator, an 

 education coordinator, and one or more 

 enforcement officers. NOAA intends that 

 Sanctuary enforcement personnel will 

 work closely and cooperatively with NMFS 

 in supporting that agency's fisheries 

 enforcement efforts. The Sanctuary's 

 education program will be developed in 

 greater detail following designation; 

 information concerning traditional and 

 current fisheries within the Sanctuary 

 may be considered. NOAA anticipates that 

 the proposed Sanctuary Advisory Commit- 

 tee may also address the development of 

 education programs. Lilcewise, the 

 Council may also address the fisheries 

 research needs of the Sanctuary, through 

 coordination with Sanctuary personnel. 



Dear Mr. Uravitch: 



The Stellwagen Bank Coalition welcomes this opportunity to offer the foUowing 

 comments and recommendations on the DEIS/MP for the proposed Stellwagen Bank 

 National Marine Sancmary (SBNTMS). This letter expands upon our oral testmiony 

 presented at the public hearings held from March 11 - 18, 1991. Your careful 

 consideration of these comments and their inclusion in the administrative record is 

 appreciated. 



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