rc:~:Uh'(Lt. Cdr. Gold, U.S.C.G.. P-^^ =---^^2 y t "^ 

 data do not include any documented vessels, and therefore are likely 

 represent mininium sanctuary usage numbers. 



While the DEIS/MP discusses in some detail vessel '^^"'^."^f '^ J° 

 commercial whalewatching {pp. 63-681, sportfishing (pp. ^^'f ' ' * „„,^„,^., 

 commercial shipping (pp. 69-75), little attention is given to he potential 

 impact on sanctuary resources of recreational boaters. The DEIS/MP 

 : ommenSs including commercial shipping traffic -'hin he scope of future 

 re<nilations based on its potential for marine mammal strikes, yet data 

 recently compiled by the Center for Coastal Studies indicate 'hat, in fact, 

 most vessels strikes on whales may be caused "/relative ysmal boats, as 

 evidenced by the size of the wound and noticeable propeller scars (see 



m :: i h^tographs). While these strikes by -^""J"" ^^^^.^^ '" 

 all probability result in as high a percentage of »°^'^l'^"„!:°"°„*''tmoact 

 animals hit, there can be little doubt that they represent a negative impact 

 on sanctuary resources (i.e. endangered marine mammals). 



currently, 23 of the approximately 600 humpbacks in '1]^ f ^^^^[J°^^^°^f ^| 

 Studies' file population (3.8X) exhibit scars presumed to be indicative ot 

 vessel collisions; of these, 1989 was the first year during which we saw 



: Lrof the smaller propeller scars illustrated in t e accompany ng 

 Photographs. Of the 313 fin whales in our file population 2- ('.UX) 

 exhb vessel-related scars. Of the 300 North Atlantic right w a es 

 identified in the New England Aquarium's Photographic ""1°?' ^'^i^^"*^ 

 also exhibit vessel-related scars. (It should be noted 'hat the numbers 

 quoted by NCAA on page 74 of the DEIS/MP regarding ;'"=f ^^'^'^^^i^^' ■„ 

 North Atlantic right whales are incorrect, "-^ are based on a misprint in 

 the Northern Right Whale Recovery Plan. The 60X figure in fa.t refers to 



entanglement scars, per personal communication with Scott Kraiis, 1991. 

 Collision scars are as noted above.) 



We agree with NCAA that, based on the potential '".'"'"^ ■!°"\„f f ^^^ 



.ortalities caused by collisions with s ips, £2SMri£.i^h^EMM^^ 



^hniild be suh i»-t to regulation (page 154). However, tne a 



indicate that for consistency, n-rreational vessel traffic should be 



-". ">%"";,1.Hnn as well . We do not agree that including such traffic 



w thin the sc^e of regulat o n would be any more duplicative page 155) than 



NOM-s proposarto lisrcom.ercial shipping traffic as . regulated activity. 



The whalewatching regulations currently being developed "^ ^he Jlational 

 Marine Fisheries Service will cover both commercial and P^'y^^^J^^^^^^^ 

 engaged in whalewatching. However, we have no evidence 'hat whalewatching 

 "ssels and shipping traffic are the only —« = ^^^^'" i^f, , ° '''''' 

 whales. Since regulation of recreational, sportfishing, commercial 

 shtppt^g, or ferry service vessels simply traversing the Bank """Id be 

 ^u sue if the scope of the proposed whalewatching "^^^'-^'^f^J^'" ^ „ 

 vessel traffic regulation may be required. The recommendation of the Center 

 for Coastal Studies that both commerical shipping and recreational vessel 

 traffic be subject to regulation is the recommended position of tne 

 Stellwagen Bank Coalition. 



Thank you again for the opportunity to comment on the proposed designation 

 of^he Stellwagen Bank National Marine Sanctuary. We will continue to 

 follow its progress with great interest, in the hope that future designat on 

 wtll provide "he overall management and protection that this area so richly 

 deserves. 



11. Comments noted, and information 

 referenced at PART TWO, Section II. C. 3, 

 See generic responses K.l. and K.2. 



Sincerely, 



Kpi-'OLo (y^ 



X-^' 



Ct.oL" 



Steuer 



of Conservation and Educational Programs 



Page G55 



