c 



2. 



9. 



There are some technical portions of the DEIS which must 



"^ "^Landings data and general information on the fisheries is 

 poor. I find the description of fishing gear on pages 62-63 

 to be emotional, haphazard and technically incorrect. ^1='^^ and 

 mobUe gear fishermen are willing to worK with ^°- ^l'°\llll\^ 

 a more accurate description of fishing techniques at Stellwagen. 

 - Another technicality involves number eight of the regulatory 

 alternatives on page 152. The Migratory Bird Treaty Act should 

 be cited in context with the Marine Mammal Protection and the 

 Endangered Species Act. I. therefore, question the l°g>;= °f 

 ifl including seabirds in the scope of regulations for this 



"""^Although commercial cargo traffic is included under ^^t^^ities 

 that may be subject to regulations in the future, it seems that 

 recreational vessel traffic should also be included in the scope 

 of future regulations for the same reasons. 



Several fishing organizations have been a pa-- =£ '^"e 

 public process for designation of this sanctuary, /^^ff^ 

 include the following organizations in your list o. National 

 and Regional Interest Organizations: 



Massachusetts Lobstermen's Association 

 Massachusetts Inshore Draggermen's Association 

 New England Gillnetter's Association 

 Stellwagen Bank Commercial Fisheries Cooperative 

 Fishermen are loolcing for the good this sanctuary can 

 bring but are afraid the draft documents fall short due to 

 compromise on the most important environmental issues. 



Sincerely, 



6. Information on fisheries landings and 

 fishing gear in the Stellwagen Bank area 

 have been updated and revised in the 

 FEIS at PART TWO, Section II.C.l. 



7. A discussion of the Migratory Bird 

 Treaty Act (HBTA) has been added to the 

 FEIS at Appendix B. See also generic 

 response L. 



8. See generic response K.l. 



9. Conunent noted. NOAA has added these 

 organizations to the FEIS distribution 

 list. 



i inctji e J. V , 

 /Janice Comeau Anderson 



general aanager 



^oaIotv. .J^oAAocAuAelii. 0S-/25 -3393 



Urban Harbors Institute/Envirorunental Sciences Program 



4/1/91 



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, DC 20235 



Dear Mr. Uravitch, 



1. 



The following are comments regarding the Draft Environmental Impact 

 Statement/Management Plan on the designation of Stellwagen Bank as a National 

 Marine Sanctuary. First, we would like to conunend NOAA on its proposed 

 regulations to prohibit (1) offshore industrial materials development, (2) the taking 

 of marine reptiles, marine mammals, and seabirds, (3) wastewater discharges within 

 the sanctuary, (4) the alteration of, or construction to, the seabed, (5) the placement 

 of submerged pipelines and cables, (6) the removal, taking or injuring of historical 

 or oiltural resources, and (7) the discharge of trash and other debris. These 

 regulatioriS provide NOAA witii a strong regulatory foundation wiJi which it can 

 effectively manage and protect sanctuary resources and uses. 



Furthermore, we agree with NOAA's preferred management alternatives of 

 placing the operation of commercial vessels and charterboats as activities subject to 

 future regulation. The potential impact of these activities on sanctuary resources 

 and uses may be very significant, but is not currently well understood. We 

 recommend study and research as part of the proposed sanctuary management plan 

 to assess this impact However, we think boundary alternative «2, NOAA's 

 preferred alternative, and proposed regulations for: (1) dredged material disposal, 

 (2) oil and gas development, (3) mariculture, and (4) recreational vehicle activity are 

 inadequate to meet the primary goal of the sanctuary program— enhanced protection 

 of resources and uses. 



UNIVERSITY OF MASSACHUSETTS/ BOS TON, 

 URBAN HARBORS INSTITUTE/ENVIRONMENTAL 

 SCIENCES PROGRAM 



1. No response necessary. 



Page G90 



