3 



2. With regard to management alternatives, the ACS favors 

 alternative /3. Initial nomination of Stellwagen Bank as a national 

 marine sanctuary was made in 1983. If management alternative /3 is 

 adopted, the new sanctuary would certainly be headquartered and 

 staffed by the beginning of 1993. A decade is a long time to have 

 waited, but given past circumstances, we would feel satisfied if 

 the sanctuary were fully operational by that time. In contrast. 

 Alternative /2 offers no certain time by which the sanctuary would 

 be fully staffed and operational. This is not acceptable in our 

 view. 



3. We recommend location of the primary Sanctuary headquarters 

 either at Boston or Plymouth, with satellite offices at Gloucester 

 and Provincetown. Headquarters at Boston would provide a 

 geographically central location, a politically central location 

 facilitating coordination between offices of the State of 

 Massachusetts and various Federal agencies; and easy access for 

 many people. Headquarters at Plymouth would also be reasonably 

 central geographically, less central politically, but would be 

 nearer to Stellwagen BanX itself. Location at Plymouth could also 

 take advantage of the large number of visitors to the Plymouth 

 Plantation/Mayflower site, and planned construction of a new whale 

 museum coordinated by the New Bedford Whaling Museum. Whichever 



location were Elected, satellite offices should be located at 

 Gloucester and Provincetown. Those towns are the major ports of 

 access to Stellwagen Bank, via numerous scheduled whalewatch trips 

 and fishing trips. They will be effective sites for research, 

 education and interpretive activities. 



4. ACS is in general agreement with regulatory alternatives 

 recommended as "preferred" in the DEIS, with the following comments 

 or exceptions: 



a. Discussion of the potential impact of sand and gravel 

 mining (pp.7£) should mention the importance of the sandy 

 substratum to sand lance. Those fish burrow in the sand 

 during the day and possibly during longer periods of 

 inactivity at the end of summer or possibly at other seasons. 

 Deleterious effects on populations caused by disruption of the 

 substratum could cause serious detrimental effects to 

 cetaceans, seabirds and fish populations used by commercial or 

 sport fishermen. 



b. Aemaculture should be prohibited within the Sanctuary , 

 recognizing potential entrapment or entanglement of cetaceans, 

 production of waste-products, or pre-emption of other 

 desirable activities. 



"b. Offshore hydrocarbon development should be prohibited 

 within the Sanctuary . It is not compatible with other 

 essential Sanctuary uses identified in the DEIS. 



c. Removing, taking or injuring historical or cultural 

 resources should not be prohibited . Instead these activities 



i 



S. 



(>. 



?. 



should be allowed subsequent to receipt of a permit issued by 

 the Sanctuary Manager in concert with other involved agencies. 

 It is possible to envision circumstances under which removal 

 might be a preferred alternative for purposes of display, 

 scientific study, or other reasons. 



d. Operation of vessels . ACS agrees with DEIS preferred 

 alternatives for managing commercial vessels and charter 

 boats. However, some provision for managing recreational boats 

 should also be enacted . The Sanctuary Management team may 



have enough to do during initial years without actively 

 "managing" the numerous small vessels that visit the 

 sanctuary. However, the plan should include provision for such 

 actions at an appropriate time, depending on need. However, an 

 informational program for owners and operators of such boats 

 should be initiated immediately to minimize their impact on 

 ^etaceans and to promote other Sanctuary goals. 



5. The Reference List should include sources for all documents 

 cited in the text. A number of government documents were cited, 

 but not listed, including the NMFS Humpback Recovery Plan, NKFS 

 Right Whale Recovery Plan; NMFS Whale watching Guidelines; U.S. 

 Army Corps of Engineers (1988); and DAMOS documents. Listing in 



L: 



References will enable the reader to obtain those documents when 

 needed. S<.-<J- ty j^j-ro-Ve. cevtf 



6. I enclose a reference list on cetaceans of the Gulf of Maine and 

 eastern Canada which includes several publications that should have 

 been included in your reference list. Those publications are 

 highlighted on the list. 



3. Comments noted. See PART THREE, 

 Section II. B. NOAA intends that, at a 

 minimum, a Sanctuary Manager will be 

 hired and an office facility will be 

 established in Plymouth, MA by the time 

 of final designation. Other Sanctuary 

 staff will be hired thereafter. 



4. Comment incorporated at PART TWO, 

 Section II. C. 7. 



5. See generic response G. 



6. See generic response E. 



7. See PART THREE, Section II.C.6. 



8. See generic response K. 



9. Comments noted. Corrections to the 

 "References" section have been made. 



Page G50 



