American Cetacean Society 



April 7, 1991 



Mr. Joseph A. Uravitch, Chief 



Sanctuaries and Reserves Division 



Office of Ocean and Coastal Resource Management 



National Ocean Service/NOAA 



1825 Connecticut Ave., N.W. 



Suite 714 



Washington, D.C. 20235 



Dear Mr. Uravitch, 



On behalf of the American Cetacean Society I an pleased to offer 

 the following comments on the Draft Environnental Impact Statement 

 (DEIS) for the proposed Stellwagen Bank National Marine Sanctuary. 

 As Co-chairman of the NMFS Humpback Whale Recover Team and a member 

 of the Right Whale Recovery Team, I know firsthand the challenge of 

 preparing a document like this DEIS, and I complement your 

 division. Project Manager Sherard Foster, Program Specialist 

 Patmarie Maher and Bradley Barr (Massachusetts Critical Zone 

 Management Office) for preparing a well-organized, comprehensive 

 and carefully-edited document. 



The American Cetacean Society, founded in 1967, is the oldest 

 cetacean conservation organization in the United States. The ACS 

 mission embraces education, research and conservation of cetaceans 

 and their habitats. On behalf of our 3,000 members, now 

 representing 37 countries, I wish to register our strong support 

 2_ for the creation of a Stellwagen Bank Sanctuary within the National 

 Marine Sanctuary Program. The DEIS adequately summarizes the 

 desirability and need for this designation. Simply put, Stellwagen 

 Bank is extraordinary. Other places also have high fisheries 

 productivity and abundant populations of cetaceans and seabirds, 

 but nowhere else on the U.S. east coast are these resources located 

 so close to major metropolitan areas. Geographic proximity and an 

 existing infrastructure make it possible for over a million people 

 to visit Stellwagen Bank each year, introducing them to the Bank's 

 marine fauna and some of the issues involved in conserving them. 

 Naturalist interpretation on whale watch tours offers outstanding 

 potential for marine education. 



The whales, dolphins and porpoises are Stellwagen Bank's most 

 visible animals, attracting most of its visitor^sand thereby 

 generating much of the Bank's current economic va'lue for the 

 surrounding region. The current presence of these animals serves 

 as an indicator that productivity at all trophic levels is also 

 high and that environmental quality is satisfactory. Maintaining 

 those conditions will be necessary for whales to continue using 

 Stellwagen Bank in the future. It is possible to imagine Stellwagen 

 Bank with productive fisheries and no whales, but the region would 



be poorer economically and opportunities for education would 

 decrease. The Bank would lose much of its appeal to the average 

 citizen. Therefore, education and management initiatives dedicated 

 to maintaining healthy cetacean populations and a clean, productive 

 Stellwagen Bank habitat will benefit all of us and all of the 

 organisms in that ecosystem. Management supervision by a Sanctuary 

 Manager and Advisory Committee, as specified in the DEIS, will help 

 guarantee that Stellwagen Bank will always remain the special place 

 that it is today. 



ACS offers the following specific comments on the DEIS. 



1 With regard to sanctuary boundaries, the ACS strongly supports 

 Alternative /3. As stated in the DEIS (p. 173), management 

 planning under that alternative would be developed more from the 

 perspective of ecosystem relationships and interdependence. In our 

 opinion, that is exactly how it should be done. The benefits of 

 borders contiguous with the North Ocean Sanctuary, South Essex 

 Ocean Sanctuary, Cape Cod Bay Ocean Sanctuary and Cape Cod Ocean 

 Sanctuary; and cooperative management with agencies overseeing 

 those adjacent state sanctuaries are extremely valuable. Those 

 benefits outweigh the marginal costs of administering a larger 

 sanctuary. Since Alternative /3 is still much smaller than some 

 sanctuaries already existing within the National Marine Sanctuary 

 System, we have full confidence that Boundary Alternative /3 can be 

 successfully managed. Boundary Alternative #3 includes the 

 Massachusetts Bay Dump Site (MBDS) within Sanctuary borders. We 

 would not oppose continued use of the MBDS overseen by Sanctuary 

 managers and other involved agencies. The DEIS makes a strong case 

 for this option. 



AMERICAN CETACEAN SOCIETY 

 1. No response necessary. 



2. See generic response B.l. 



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