As you know, the Slellwagen Banlc Coalition consists of over 100 grassroots coastal 

 community groups, environmental organizations, fishermen, educators, individuals and 

 others who are working toward securing the designation of Stellwagen Bank as a National 

 Marine Sanctuary. Please see enclosed membership list. The Coalition has collected 

 over 16,000 signamres in suppon of the designation. Through efforts including the 

 development of a conference, a technical report on the area, workshops, a slide show, 

 and fact sheets, the Coalition has educated thousands of individuals and organizations on 

 the importance of protecting the Bank's resources. 



While we feel that in general you have put forth a responsible DEIS/MP, there 

 are key areas - the sanctuary's boundaries and the issue of the Massachusetts Bay 

 Disposal Site (MBDS) to name' but two - where we find that your proposal fails to offer 

 the safeguards necessary to promote long-term, comprehensive resource protection that 

 is the fundamental obligation of the NMSP. 



Boundaries 



The national signiScance and sensitivity of the Stellwagen Bank region dearly 

 demand that it be afforded the strongest possible protection through the largest feasible 

 boundary. In additiotv Title Hi's directive that the purposes and policies of NauoiKa 

 Marine Sancniaries are "to provide authority for cornprehensive and ^oo^dmated 

 conservation and management of these marine areas that wiU complemen ex^nng 

 e^faTory authorities- {Sec. 301 (b) (2)} can be best met by a Nauon^ Manne 

 S^ctua^ that abuts the state ocean sanctuaries. Therefore, fh. Stellwagen Bank 



L,.nd.rv fnr the -^..U^r" """l^ N.tinn.l Marine San^m, In our v^e*. both 

 ecosystem protection and manageabiUty favor the adopuon of this boundary alternative^ 

 Boundary alternative #3 offers the oppormnity to provide long-term protecnoii and 

 comprehensive management of the Stellwagen Bank system emphasized m your plan. 



In addition, in order to facilitate navigation for users of the area, boundary 

 coordinates should be shown with Loran C lines. 



There are three major reasons why the Coalition recommends Alternative #3 as 

 the boundary for the Stellwagen Bank National Marine Sanctuary. 



First, we dispute the apparent conclusions reached in the DEIS/M? that the 

 preferred boundary alternative (alternative #2) includes the entirety of the imponant 

 local habitats for sanctuary fishery and marine mammal resources. Living resources will 

 move across any human designated boundary seasonally and will utilize different ^eas 

 from year to year. Although such movements may make it impossible to draw 

 boundaries that include all important habitats, alternative #3 includes those that are most 

 important to the resources of this system The DEIS/MP confirms this on page 13 1_ 

 In particular, alternative #3 includes key habitats just east of the Stellwagen Bank 

 feamre Tillie's Bank and the southern ponion of Jeffrey's Ledge, which are trussing from 

 the preferred boundary alternative. Several speakers at the Stellwagen Bank Conference 

 in April 1990 expressed the importance of all of these habitats for the resources of this 

 area. These areas are heavily utilized for feeding, nursery and spawning purposes by the 

 same marine mammals and fishery populauons that frequent Stellwagen Bank. Inclusions 

 of these key areas would greaUy increase the Ukelihood of comprehensively protecung 

 important sanctuary resources without greatly inCTeasing its size. 



Secondly, boundary alternative #3 extends to and abuts four state ocean 

 sanctuaries As noted above, this connertion will provide for comprehensive management 

 of the area- We believe that this link will better facilitate coordination between state 

 and federal programs on marine protection and management issues as recognized ui the 

 DEIS/MP for the Cape Cod Bay state sanctuary. Since the Commonwealth ot 

 Massachusetts has formally expressed its support for the sanctuary and .boundary 

 alternative #3 a link between the National and State programs will be beneficial tor the 

 protection of the resources. It will also allow NOAA to pursue and to encourage the 

 best available management practices to minimize land-based pollution including point and 

 non-point sources that could potentially damage the area's resources 



Thirdly alternative #3 encompasses all of the proposed Massachusetts Bay 

 Disposal Site. This inclusion will allow for adequate monitoring of the resources if tius 

 site continues to be used. It wiU also provide another level of protecuon to ensure that 

 this activity does not damage the sanctuary's manne resources. 



NOAA's -prefened- boundary alternative #2 does not encompass all of the area;s 

 critica] resources and habitats. In fact, NOAA seems to recognize this m the DEIS/MP 

 on oaee 173 and 131. In addition, because many of the resources do move m and ou 

 of Siese areas, boundary alternative #2 does not adequately protect the r.«°""^, " 

 suggests it wS from several activities that threaten them. TTiese activiues mclude the 

 Suon and disturbance of the sea bed (through the development of artifical islands 

 or mining), hydrocarbon development, aquaculture and the leakmg of pipelmes. 



STELLWAGEN BANK COALITION 



1. See generic responses B.l. and B.2, 

 See also expanded discussion at PART 

 THREE, Section II. A. 2. Regarding the 

 inclusion of the MBDS within the pro- 

 posed Sanctuary, see generic response 

 D.l. 



Page G83 



