7. 



Cn the qusEticr. of the regulaticn cf dredged aaterial 

 disposal within sanctuary boundaries, CLF strongly supports the 

 preferred alternative in the DEIS/MP — allowing disposal at MBDS 

 with sanctuary oversight, but prohibiting it elsewhere. CLF 

 believes that there is no unacceptable harm from the open ocean 

 disposal of dredged material that is clean, but dredged material 

 containing persistent, toxic contaminants can present a threat to 

 the marine environment if dispersed in the ocean. The current 

 regulations governing the open ocean disposal of dredged material 

 leave considerable latitude in judging what level of contaminants 

 is acceptable, and CLF believes that it would be beneficial to 

 the Stellwagen Bank region to have oversight by a NOAA office for 

 which the primary concern is protection of marine resources. 



7. See generic responses D.l. and D.4. 



?- 



?. 



Finally, we recommend that the following three activities be 

 added to the list of activities subject to regulation under 

 Article IV (Scope of Regulations) of the designation document: 



(1) operation of recreational vessels 



(2) lightering of hydrocarbon products (oil and gas) 



(3) incineration of waste materials. 



I would like to note, in closing, that CLF has no objection 

 to the regulatory revisions proposed by the New England Fishery 

 Management Council pertaining to management authority for 

 activities subject to the Kagnusc.-. Act. 



Thank you for your consideration of these comments. 



Sincerely, 



C-^ia-r^— >^ y^L. 



Eleanor M. Dorsey 

 Staff scientist 



8 . See generi 



c responses K.I., f. and H. 



9. See generic response N. 



THE GLOUCESTER FISHERMEN'S PROGRAM 



a branch o/ OiiUrfni Fntrrui oW fijniii\ Sfn-i« SocifO o/ ^^<: S'onh Shore. Inc. 



Broun's Mall ■ 1S6 Main Sctret 



Ciouc«ter, Massachusens 019)0 ■ 503-:33-:5O4 



April 5, 1991 



Joseph A. Uravitch, Chief 



Sanctuaries and Reserves Division 



Office of Ocean and Coastal resource Management 



National Ocean Service /NOAA 



1825 Connecticut Avenue, NW. Suite 714 



Washington, D.C. 20235 



Dear Mr. Uravitch: 



Participating in the review of the proposed National 

 Marine Sanctuary status for Stellwagen Bank as a member of 

 the Stellwagen Bank Coalition representing the Gloucester 

 Fishermen's Program has been very inspiring. 



The Gloucester Fishermen's Program is a program under a 

 social Service agency. It is our duty to assist fishermen 

 and their families during times of crisis in their lives. It 

 is also our responsibility, to help protect their economical 

 wellbing. Economic stability plays an important part in the 

 strengthening of a family live. 



In upholding our commitment to the fishermen and their 

 families we must take issue with the proposed designation 

 for Stellwagen Bank as a National Marine Sanctuary. 



The Gloucester Fishermen's Program endorses the 

 designation of Stellwagen Bank as a National Marine 

 Sanctuary. Enclosed is a summery of our recommendations to 

 be considered in the regulations. 



We are very pleased to have been given the opportunity 

 to work very close with Ms. Sherrad Foster and Mr. Thomas 

 Bickfor of your agency and Mr. Brad Barr of the 

 Massachusetts Coastal Zone Management office. 



We feel that with the proper guide lines the 



designation of Stellwagen Bank as a National Marine 



Sanctuary is going to benefit the weellbeing of our 

 fishermen and their families. 



Sincerely yours, 



Page G68 



Angela Sanfilippo ' X' 

 Program Coordinator 



