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Discharges/Deposits: One of our greatest concerns Is the Issue of the MBDS. particularly 

 the decision-making process for determining what materials are appropriate for 

 deposition. The DEIS proposes a prohibition on the discharge or deposit of materials 

 from without or outside of the sanctuary (with the exception of normal vessel operations) 

 that would have an adverse effect on the resources of the SBNMS. 



What is not clear enough is how NOAA, the EPA. the COE. and the MBDS officials will 

 determine what Is "clean". We feel the strictest protocols should be employed when 

 making this determination. This Is particularly Important considering the major projects 

 in Boston Harbor which will Involve major dredging/dumping (scheduled dredging of 

 Boston Harbor, construction of the new harbor tunnel, etc.) in the next decade. The 

 sediments from this region are known to contain slgnliicant concentrations of toxic 

 materials which could represent an equally significant threat to the resources of the bank. 



Further, permanent designation of the MBDS would result In deposits over the long term 

 and. therefore, the greatest threat could result from the accumulated toxins over time. 

 NOAA should be Involved In all phases of this process to actively Insure that materials 

 deposited are consistent with the goals and purpose of the SBNMS. In addition. NOAA 

 should immediately Institute an aggressive monitoring program to pursue these alms. 

 Current plans for monitoring only extend 200 yards from the dump site. We feel this 

 should be extended to a Tninimum of 1/2 mile. 



Similarly, the new Massachusetts Bay outfall tunnel will Introduce hundreds of millions of 

 gallons of treated sewage into Mass Bay dally. Studies of the dominant currents prevailing 

 in Mass Bay strongly suggest that these materials will pass through the SBNMS. The 

 Introduction of these organlcs. as well as the dissolved toxins also Involved, could have 

 dramatic effects on the bank. NOAA should coordinate efforts with appropriate agencies 

 In seeking the highest quality e£Quent possible. This should include insistence on at least 

 secondary level treatment of the sewage as soon as possible. 



Vessel Traffic: CRU concurs with NOAA's recommendation to put corcmerclal traffic 

 under the scope of regulations and to research this type of activity. We feel that 

 recreational trafEc should also be subject to these regulations, and similarly researched. 



Our data, and the research of several other organizations in the area, demonstrate that an 

 increasing number of whales have been struck by the propeller blades of boats. Based on 

 the size and spacing of the scars, many of these Injuries appear to have been the result of 

 collisions with smaB vessels. In some cases, vessel strikes of whales have resulted In very 

 serious injury, or death. 



The rapidly growing number of boats registered In state waters (nearly 40.000 registered 

 since 1987). as well as the general Increase In the speeds of boats using the Stellwagen 

 Bank region, could lead to more Incidents of these whale/vessel collisions. In addition, 

 the risk of a collision is increased by the very heavy use of the northern and southern 

 extremities of the bank by sport fishing boats (esp. tuna boats), as well as by whales. Many 

 of these sport boats move Into position at night or In poor light, or at high speeds or both. 

 This only raises the risk of a collision and the severity of the injury. We recommend that 

 NOAA consider Imposing a 'speed limit' within the sanctuary. Discussions among many 

 user groups. Including maritime captains, has resulted in agreement that 18 knots would 

 be an acceptable maximum speed. Presently there are many vessels that routinely travel 

 at 20 - 30 knots in these waters. 



With regard to commercial shipping traffic, the DEIS notes that this traffic will "be 

 dominated by the movement of petroleum". In light of the significant spills in recent 

 years in U.S. waters, and considering the distinct possibility of an accident In the 

 Stellwagen Bank region at some point, we feel it would be Imperative for sanctuary 

 officials to recognize this possibility and become Invohwd in formalizing an emergency 

 action plan, including the instjollaiion of the necessary equipment in the Immediate area, 

 to respond to such an occurrence within, or adjacent to, the SBNMS. A vessel traffic 

 system, analogous to an Air Traffic Control Tower system, may be worthy of investigation 

 for the purpose of minimizing the risks of collisions In the sanctuary, particularly with 

 the major shipping lane already established there. For example, this tnay be useful In 

 alerting large vessels of the presence of concentrated groups of whales or fishing boats. 



3. See PART THREE, Section II. C. 

 See also generic response D.4. 



l.A. 



4. See generic response C.2. 



5. See generic responses K.l. and K. 



T^T B% ^u"^^^°" '^^ PA^T TWO, Secti 

 III. B. 3. The Sanctuary contingency 

 plan will address the issues of 



f!^f!f?^rP''^P^"'^^==' including 

 installation of necessary equipment 

 at appropriate Ip^^^r^^^ ^ 



