12. 



'3. 



/4. 



♦ Ipp. 154-51 The DEIS/MP appropriately places the operation of commercial vessels 

 within the scope of regulation. However, there Is strong evidence that the growing 

 number of recreational vessels In the Stellwagen Bank area are adversely Impacting 

 the resident and transient cetaceans of the area. Specifically, researchers at the 

 NEAq and the Center for Coastal Studies have photo documentation of several 

 different species of cetaceans with scars characteristic of small propellers (see 

 comments submitted to you by the Center for Coastal Studies). Although these 

 Injuries are not as life threatening as those sustained during encounters with larger 



vessels, they compromise the animal's health, ability to feed, reproductive capabili- 

 ties, and ability to escape predators. For these reasons, we recommend that recre- 

 ational vessels be placed within the scope of regulations. Research should be 

 conducted to determine if further regulatory actions should be taken with regard to 

 both commercial and recreational vessel traffic. 



♦ Ipp. 145-61 We are interested in the potential for aquaculture projects to help 

 conserve wild fish stocks in the future; Indeed, such projects will have their place 

 within the scheme of ocean uses in other parts of the Gulf of Maine. However, 

 aquaculture projects must be carefully sited, to avoid negatively Impacting other 

 ocean resources. 



We believe that aquaculture activities on Stellwagen Bank are incompatible with the 

 goals of the sanctuary program, for a number of reasons. First, such activities 

 create a potential for the entanglement of marine mammals, reptiles, and seabirds. 

 Secondly, the strings of pens create a navigational hazard. Third, such activities 

 would constitute an exclusive economic use of an area deemed a special public trust. 

 Finally, the large area of ocean required for such activities would consume a con- 

 siderable amount of the ecosystem the program seeks to protect. For these reasons, 

 we recommend that aquaculture projects be prohibited within the sanctuary, 



♦" |p. 1341 We agree with the DEIS/MP that "...these staff and facilities are likely 

 to be necessary to a successful Sanctuary program." Hence, we feel that the selec- 

 tion of Management Alternative 3 should be the preferred alternative. Every aspect 

 of the sanctuary program (education, research, management, and enforcement) rests 

 upon a firm commitment to full staffing and funding. 



Once again, on behalf of the New England Aquarium. I extend our appreciation for a 

 fine Job in developing the DEIS/MP for the Stellwagen Bank National Marine Sanctu- 

 ary. We are committed to working with NOAA and citizens to help secure an 

 effective sanctuary for Stellwagen Bank. We look forward to working with you and 

 your staff In the months ahead, and await your response to these comments. If you 

 have any questions, please feel free to call me at (617) 973-5454. 



12. See generic response K.2. 



13. See generic response G. 



14. NOAA agrees that full implementa- 

 tion of appropriate staff and 

 facilities is necessary to ensure a 

 successful Sanctuary program. 



sincere! 



Conservation Assistant 

 New England Aquarium 



New England Fishery Management Council 



5 Broadway • Sausus, Massachusetts 01906 

 (617) 231-0422 FTS 83S-84S7 



Chairman 

 Ree«rtA.Jone3 



EiacvtTMe O^raow 

 OougtAtG. Manftall 



April 5, 1991 



Mr. Joseph Uravitch, Chief 

 NOAA /Sanctuaries and Reserves Division 

 1825 Connecticut Avenue, NW, Siiite 714 

 Washington, DC 20235 



Dear Mr. Uravitch: 



The New England Fishery Management Council appreciates the opportunity to 

 discuss again the proposed Stellwagen Bank National Marine Sanctuary. Before 

 offering comments on the proposed rtile, we would like to acknowledge the efforts of 

 your agency and in particular Ms. Sherrard Foster to coordinate with the Council. 

 Additionally, Mr. Brad Barr of the Massachusetts Coastal Zone Management Office 

 has regularly attended the Council's Habitat and Environment Committee and 

 Council plenary meetings and has offered much helpful advice. 



Page G80 



