^ 



NED si^ports the sanctuary designation and the preferred sanctuary 

 bourdary alternative identified in the DEIS, but believes that existing 

 regulations on the ocean disposal of dredged material are protective of the 

 environment (See Corps of Engineers' Site Evaluation Docurent and E3>A's 

 Environmental Impact Stater^nt for the Massachusetts Bay Disposal Site) and 

 sufficient to protect sanctuary resources. "ITie DEIS proposes a sanctuary 

 certification process (i.e. a permit) to insure that dredged naterial 

 disposal is consistent with sanctuary regulations but does not define the 

 guidelines or criteria that would be used by NOAA to- determine consistency. 



NOM has not clearly de-Tonstrated the need for additional regulations. 

 Instead we propose the development of a me-iiorandim of u.Tderstanding (MOU) 

 among COE, EPA and NOAA which will achieve the purpose of assuring 

 coordinated and ccrprehensive management of Sanctuary resources without the 

 extra layer of regulation. 



NED currently coordinates disposal activities at KEDS with EPA, 

 NOAA/NMFS, and USFWS. We welccme increased participation by NQAA/Sanctuaries 

 m the e-xisting revie"v process and recommend that the NCAA review nc7.v vested 

 in NKFS te e.Npanded to include NOAA/Sanctuaries. This participation alcng 

 with the >DC' will facilitate corpre^iensive and coordinated na.'-agament of the 

 Sanctuary. As NOAA develops a monitoring strategy for the Sanctuary, NED 

 will provide technical assistance on issues dealing with dredged material 

 disposal. We believe the results of this monitoring prcgra-Ti should be used 

 to assess adequacy of e-xisting management practices. 



Attached is some reconmended language for the portion of the FEZS dealirq 

 with dredged material disposal. We lool< for.vard to working with your staff on 

 the Final Environnental Iirpact State.Tient and to the development of the M3U. 



DEPARTMENT OF THE ARMY 

 New England Division, 

 Corps of Engineers 



1. No response necessary. 



2. See generic response D.4. NOAA 

 intends to pursue the development of a 

 MOU with COE and EPA to identify NoL's 

 role in the review process for disposal 

 permit applications, and to involve NOAA 

 m continuing monitoring of the MBDS 



No response necessary- 



sincerely 



Q}i\i^ 



Ftiilip R.l 



Colonel, Cbrps of Engineers 



Division Engineer 



, UNITED STATES OEPAPtTMENT OF COMtVIERCE 

 National Oceanic and Atmospheric Administration 



NATIONSL MARINE fISMERIES SEHVrtCE 



jNortheast Region 

 Habitat and Protected 



Resources Division 

 One Blackburn Drive 

 Gloucester, HA 01930-2298 



April 8, 1991 



Joseph Uravitch 



NOAA, National Ocean Service 



OCRM, Sanctuaries and Reserves Division 



1825 Connecticut Avenue, NW, Suite 714 



Washington, DC 20235 



Ba; Conments - Stellwagen Bank National Marine 

 Sanctuary Draft Environmental Impact Statement 



Dear Mr. Oravitch: 



Thank you for the opportunity to provide comments on the proposed 

 designation of Stellwagen Bank as a National Marine Sanctuary. 

 We support the concept, and offer the following comments to 

 strengthen the document. 



Before our specific comments, I want to applaud the document 

 preparation process adopted by SARD for this site. Susan 

 Durden's office did an excellent job of involving agencies and 

 special interest groups, and ensuring that their perspectives 

 were incorporated into the planning documents. Much of the 

 credit belongs to Sherrard Foster, but I realize that GCOS, 

 Office of Legislative Affairs, and others contributed. Based on 

 over 12 years of observing the active candidate and designation 

 process, I can attest that Ms. Foster's personal efforts were 

 outstanding. She cultivated excellent working relationships as 

 she worked with the fishery management council, embraced state 

 participation, net with all parties, and spearheaded the process. 

 Regardless of anyone's position on designation, SARD'S solid 

 staff work has certainly enhanced the process. I hope future 

 sanctuary and reserve proposals will be supported by similar 

 commitments to the planning phase and to personal liaisons with 

 field contacts. 



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