Certain features of the proposed regulatory regime for managing 

 the sanctuary and its resources are inconsistent, and therefore, 

 are of concern. In our view, these apparent inconsistencies 

 would preclude achieving the intent of the Marine Protection, 

 Research and Sanctuaries Act to protect Sanctuary resources on a 

 holistic, or systera-wide basis. A consistent regulatory approach 

 needs to be devised for the proposed sanctuary. 



Thank you for the opportunity to comment on this Draft ZIS for 

 the Proposed Stellwagen Bank NMS. 



Sincerely, 



"^^2^^^ 



><lr^ 



ED CASSIDY 

 Deputy Assistant Secretary - 

 Policy, Management and Budget 



Specif i c Comments 



^. 



Page 10. F. Purpose and Need for Desi gnation: In the first 

 paragraph, it should be noted that large populations of sand 

 lance also are essential for seasonal concentrations 'of most 

 seabirds. The second paragraph should note that birdwatchmg 

 trips are also scheduled. Although they often are combined with 

 whalewatching, they may also be conducted at seasons when whales 

 are scarce or absent. 



Pages 44-51. g. Seabirds: This section contains inaccuracies 

 that need to be addressed. Much of the information is attributed 

 to Powers (1983) and Powers and Brown (1983), neither of which is 

 included in the list of references. Actually, those publications 

 report the distribution of pelagic marine birds on Georges Bank 

 and the Gulf of Maine and not necessarily those near-shore 

 species likely to be found on Stellwagen Bank. Better 

 information is available from the Massachusetts Audubon Society 

 and from the publications: American Birds and fiird Observer. 



The "scoters," referred to on page 44, should be cited as 

 seaducks, and should also include the common eider. It should be 

 noted that these species may occur in large numbers during 

 migration or in winter. 



The next paragraph should state that various species of raptors, 

 including the endangered peregrine falcon, commonly migrate 

 across the Stellwagen Bank between Cape Cod and Cape Ann. Many 

 other migratory birds, including shorebirds and even small 

 landbirds, follow this coastal route. Some migrate in daytiae 

 and some at night. During bad weather, these birds may become 

 disoriented and temporarily alight on fishing boats and seagoing 

 vessels. 



The list of species in Table 2 was derived from texts written 

 prior to publication of the 6th edition of the American 

 Ornithologists' Union's Check-list of North American Birds in 

 1983. Corrections should include "red-necked" for "northern" 

 phalarope and "antillarum" for "albifrons" as the scientific name 

 for least tern. Many other scientific names are misspelled. If 

 they are included (which may not be necessary) , refer to 50 CFR 

 10.13 for the correct spellings. 



Page 76. 5. Offshore Oil and Gas Activity: In the third 



paragraph, we suggest adding the following sentence at the end of 

 the paragraph: "However, based on the September 25, 1990, 

 recommendation by the Director of MMS, the North Atlantic 

 Planning Area would be considered for MMS geologic and 

 environmental studies during the proposed mid-1992 to Bid-1997 

 5-year leasing program." 



DEPARTMENT OF THE INTERIOR 

 Office of the Secretary 



1. Comment noted. Corrections also made 

 to references on seabirds (PART TWO, 

 Section II.B.2.g. ) . 



2. Corrective language added to 

 discussion of offshore oil and gas 

 activitiy (PART TWO, Section II. C. 6.) 



Pages 78-81. 6. Sand and Gravel Mining: The discussion of the 



possible effects of marine sand mining on biological resources 

 does not provide any information to indicate that many of these 

 effects may be avoided or mitigated. There is a large voluae of 

 information currently available to help assess whether offshore 

 mining can be accomplished in an environmentally safe manner. 

 For example, the International Council for the Exploration of the 

 Sea (ICES) has published a comprehensive bibliography dealing 

 with the effects of marine sand and gravel extraction on 

 fisheries (ICES, 1981). There is also a literature review 

 published by Stem and Stickle (1978) dealing with the effects of 

 turbidity and suspended material on organisms resident in aquatic 

 estuarine environments, indicating that fishery resources are 

 generally not affected to a significant extent by the dredging of 

 bottom sediments. To date, almost all offshore sand and gravel 

 mining has occurred in foreign waters. Thus, considerable 

 information on ocean mining technology and environmental safety 

 exists in countries such as the United Kingdom and Japan. The 

 material in these and other references needs to be incorporated 

 into the analysis in the Stellwagen Bank NMS EIS/Management Plan. 



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