i 



The Environment Department generally supports the preferred 

 regulatory alternatives proposed by NOAA, with the exception 

 of proposed regulation of Offshore Hydrocarbon Development. 

 The NOAA prefers to categorize this type of development as 

 "subject to Sanctuary Regulation." After the moratorium on 

 hydrocarbon development in the area e.xpires, discovery of 

 additional reserves could create economic pressures favoring 

 exploration and development in the Sanctuary area. In 

 addition, the federal government, to the extent that it has 

 an energy policy, seems to encourage exploitation of 

 previously undeveloped hydrocarbon sources rather than 

 emphasize conservation and alternative energy sources. This 

 policy has the potential for creating future development 

 pressures on hydrocarbon reserves in the Stellwagen Bank 

 area. To protect this vital resource against the 

 potentially disastrous consequences of future oil and gas 

 exploitation, this Department recommends the outright 

 prohibition of all oil and gas related activities in the 

 Stellwagen Sanctuary. This point should be discussed more 

 Cully in the FEIS/M?. 



4. See generic response E. 



The designation of Stellwagen 3ank and surrounding waters as 

 a National Marine Sanctuary within the appropriate 

 regulatory framework will help protect the environmental and 

 true economic assets of the area, and will complement the 

 cleaner future envisioned for Boston Harbor. The 

 Environraen: Deoartment looks forward to reviewing the 

 FE:s/.«.?, and to the eventual designation of the Stellwagen 

 Bank National Marine Sanctuary as part of a compre.hensive 

 strategy to restore and protect the waters of the 

 Commonwealth. 



I t.hank you for your time and consideration on this matter. 



Sincerely, 



Lorraine Downey 

 Director 



'^L 



/I 



'/-U'-'l^- 



'iy 



WILLIAM F WELD 

 GOVERNOR 



ARGcO PAUL CELLUCCJ 

 LIEU TENANT GOVfONOa 



SUSAN F TIERnEV 



tecnrTARv 





(617) 727-9800 



1 April, 1991 



Mr. Joseph A. Uravitch, Chief 



Sanctuaries and Reserves Division 



Office of Ocean and Coastal Resources Management 



National Ocean Service/NOAA 



1&25 Connecticut Avenue, N'.K. 



Suite 714 



Washington, D.C. 20235 



Dear Mr. Uravitch: 



On behalf of the Commonwealth of Massachusetts, the 

 Massachusetts Executive Office of Environmental Affairs (EOEA) 

 submits these comments on the Draft Environmental Impact Statement 

 and Management Plan (DEIS/MP) for the proposed Stellwagen Bank 

 National Marine Sanctuary. The comments were developed, in large 

 part, by the EOEA Stellwagen Bank Ad Hoc Working Group, comprised 

 of representatives of agencies within EOEA, including the Coastal 

 Zone Management Office, the Department of Environmental 

 Managenent's Ocean Sanctuary Office and the Massachusetts Division 

 of Marine Fisheries, which have some interest or responsibilities 

 with respect to the regulation or management of the nearshore and 

 offshore waters of the Commonwealth. 



These comments are organized into five sections: 1) document 

 structure, 2) document adequacy, 3) sanctuary boundary, management, 

 and coordination, 4) regulations, and 5) page-by-nage coc-nents. 



Page G40 



