Thank you for the opportunity to comnent. If you have any 

 questions pertaining to these comments please feel free to 

 contact our office. 



Sincerely, 



David Wiley 



Project Director 



International Wildlife Coalition 



634 Mor.h Falmouth Highway. P^O Box 388 



ho.th Falmouth. ^l'=="':f'"""= °2",^„°^,^® 



508-554.9980 Fax 508-563-2843 



A 



1 



Massachusetts Audubon Society 



South Great Road 



Lincoln, Massachusetts 01773 



(617) 259-9500 



29 March 1991 



Mr. Joseph Uravitch, Chief 



Sanctuaries and Reserves Division 



Office of Ocean and Coastal Resource ManagemenC 



National Oceanographic & Atmospheric Administration 



1825 Connecticut Ave. NW Suite 714 



Washington, DC 20235 



RE: Draft Environmental Impact Statement/Management Plan for the 

 proposed SCellwagen Bank National Marine Sanctuary (Federal 

 Register, Vol. 58, No. 27, February 8, 1991). 



Dear Mr. Dravitch, 



Massachusetts Audubon Society, a statewide environmental 

 organization representing 49,000 Massachusetts households, strongly 

 supports NOAA's recommendation to designate Stellwagen Bank as a 

 National Marine Sanctuary. Stellwagen Bank and its associated 

 ecosystem are deserving of the national recognition and protection 

 afforded through the landmark National Marine Sanctuary Program. 



Massachusetts Audubon strongly supports many of the 

 recommendations contained in the Draft Environmental Impact 

 Statement /Management Plan (DEIS/MP) . Of particular interest are 

 those recommendations intended to maintain the ecological integrity 

 and biodiversity of Stellwagen Bank. The Society applauds the five 

 prohibitive activities cited in the draft which include dredging, 

 excavation of industrial material, installation of pipelines, 

 alteration of any historical resource and the re-tioval of threatened 

 marine organisms (i.e. turtles). 



The Society commends NCAA for their efforts in preparing the 

 DEIS/MP. It is a well-prepared and thorough document. However, 

 the Society wishes to express its reservations regarding the 

 following elements within the DEIS/MP and submits the following 

 recommendations for NOAA's consideration: 



Sanctuary Boundary - Massachusetts Audubon supports 

 Alternative « 3 as the preferred boundary delineation for the 

 Sanctuary as opposed to NOAA's preferred alternative. Alternative 

 # 3 will provide for a more complete protective management plan by 

 linking with state water boundaries. The physical, chemical and 

 biological components of the Stellwagen Bank ecosystem are closely 

 linked to the surrounding waters of Massachusetts bays and the 

 Atlantic Ocean, and thereby should be included within the 



protective sanctuary boundaries to provide for a more comprehensive 

 environmental management plan. 



Alternative # 3 encompasses Tillie's Bank and Jeffrey's Ledge 

 which play an important role for marine mammals and fin fish who 

 visit Massachusetts bays. Both areas serve as feeding and spawning 

 grounds, respectively. 



MASSACHUSETTS AUDUBON SOCIETY 

 1. No response necessary. 



2. See generic responses B.l. and D.l. 



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