Boundary Alternatives 



^. 



Boundary alternative #3, the largest, should be the preferred 

 alternative rather than the smaller 12. The immediate area of 

 Stellwagen Bank is not an independently functioning system, and 

 as such a large buffer area as possible is needed for adequate 

 protection. The reason given by the DEIS for choosing #2 over {3 

 is the higher costs of administering a vast area. However, 

 administration efforts could focus on a core area as has been 

 done for the Looe Key National Marine Sanctuary, Biscayne 

 National Park, and numerous other special management areas. At 

 some later date. Sanctuary programs could expand. In that sense, 

 a larger area would act liXe a buffer as needed. 



The Massachusetts Bay Disposal Site (MBDS) should be encompassed 

 by the Sanctuary boundary. If the MBDS is outside of the 

 Sanctuary, regulation can occur only after MBDS-related 

 environmental damage has occurred. This approach is exclusively 

 reactive. Instead, we should rely on scientific evidence that 

 certain disposal activities might affect marine resources and act 

 accordingly to limit such impacts. 



There are currently several large disposal projects proposed for 

 the MBDS that could affect resources within the proposed 

 Sanctuary. Capping contaminated material as a management option 

 is being proposed by the New England Division of the Corps of 

 Engineers. These issues can and should be addressed by the 

 Sanctuary documents. 



Acruaculture 



Aquaculture is one of eight objectives in the NMFS Strategic 

 Plan, and has recently developed into a viable industry for New 

 England waters. Culture fish could help to meet domestic demand 

 for seafood and reduce the current seafood trade deficit. 



Aquaculture relates to the Sanctuary in two ways, rirst, 

 successful husbandry is dependent on clean waters and efficient 

 operations. With those goals, aquaculturists have a special 

 interest in maintaining a viable marine environment. Second, 

 recent proposals to locate fish farms in offshore waters suggest 

 that the private sector may propose to use waters on or near the 

 Sanctuary to raise fish. The implications to other users can not 

 be ignored. However, until monitoring and research near active 

 farms can determine the extent of environmental impacts, we 

 probably do not have the information to ban aquaculture from any 

 offshore area. 



To summarize, the treatment of aquaculture in the DEIS is 

 inadequate. Discussions are limited to the current American 

 Norwegian Fish Farm proposals for inshore (Rockport) and offshore 

 (27 miles east of Cape Ann) facilities. While the Sanctuary 

 cannot terminate a permit for these facilities, if granted by the 

 time the Sanctuary is designated, renewal may be denied if they 

 are shown to adversely affect the resources of the Bank. 



Future use of the Sanctuary for aquaculture needs to be 

 addressed. Several people at the recent public meeting opposed 

 aquaculture. Their remarks were that aquaculture facilities take 

 up space and will increase marine mammal entanglements. These 

 comments seem motivated by reasons of economic competition and 

 conjecture, especially since certain fish gear and fishing 

 activities currently impose identical effects on resources. 



Marine mammal entanglements are certainly a potential problem. 

 However, for existing inshore facilities, interactions with 

 marine mammals are limited to predation by seals rather than 

 entanglement. Plans to monitor the offshore facility may answer 

 questions for that site. 



There are many valid reasons to be concerned about aquaculture 's 

 Impact on the Bank ecosystem. Because of this, plus public and 

 agency interest, acpjaculture's known and potential environmental 

 impacts should be objectively evaluated. Aquaculture, like other 

 private enterprises that restrict public use of the ocean or 

 bottom, should be identified by the Sanctuary as an activity 

 subject to future regulation. The Sanctuary might consider a 

 policy of experimental leasing. Such decision-making would help 

 foster attitudes of proactive management. 



7. See generic response B.l. 



8. See generic response D.l. 



9. See expanded discussion of 

 mariculture at PART TWO, Section 

 II.C.ll. Based on current guidelines for- 

 siting net pen finfish facilities it is 



^Kf^^.^"^^ ^" operation will e;er be 

 established within the Sanctuary NOA^ 

 proposes to list this activity as 

 subject to regulation. 



to. 



Alterati on of. or Construction on. the Seabed 



This prohibition does not apply to "normal fishing operations." 

 Rather than "normal", this should state "traditional", and should 

 apply consistently to trawling, dredging, and any other gear that 

 could contact the ocean bottom. 



10. NOAA has changed "normal fishing 

 operations" to "traditional fishing 

 operations", with regard to the proposed 

 prohibition on alteration of the seabed. 



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