on behalf of the American Cetacean Society, thank you for the 

 opportunity to comment on this DEIS. We appreciate the excellent 

 work done by your staff. 



Sincere 



even K. Katona, Ph.D. 

 President 



..T,ONA.HEA.QUARTE.S P O. BOX ^S3, SA^ PEDRO, CAUFO«N,A 9Cr3,^S« UU, S.8^"^ .AX ,=,3, S«^950 



Center for Coastal Studies 



A Pnvate Son-Prom Orgamzanon for Researth and Educanon m the Coaslal Environment 

 59 COMMERCIAL STREET • BOX 1036 • PROVINCETOWN ' MASSACHUSETTS 02657 • |508l 487-3622 



March 14, 1991 



Mr. Joseph A Uravitch, Chief 



Sanctuaries and fieserves Division 



Office of Ocean and Coastal Besource Manageaent 



National Ocean Service/NOAA 



1825 Connecticut Avenue NW 



Suite 714 



Washington, D.C. 20235 



Dear Mr. Uravitch, 



Thank you for this opportunity to comment on the Draft Environmental Impact 

 Statement/Management Plan for the proposed Stellwagen Bank National Marine 

 Sanctuary. As you know, the Center for Coastal Studies was one of the 

 original parties involved in the nomination of Stellwagen Bank for SEL 

 consideration in 1983. We have followed its progress with great interest 

 and, as one of the founders of the Stellwagen Bank Coalition, a group of 

 Bore than 100 environmental, fishing, scientific, and academic organizations 

 working toward its designation, we are delighted at NOA.^'s recommendation 

 for sanctuary status under Title III of the Marine Protection, Research and 

 Sanctuaries Act. 



The Center for Coastal Studies haa, as an institution, arguably spent more 

 time involved in research on Stellwagen Bank than any other. Our studies on 

 the behavior, abundance, and distribution of the marine mammals that 

 frequent the area can be traced back to 1975; our whalewatch-related 

 educational programs began at the same time. We now maintain the most 

 extensive database in the world on a single population of whales, and today 

 reach out to more than 150,000 people annually with educational programs 

 related to the marine life of Stellwagen Bank and the greater Gulf of Maine. 

 During the past 16 years we have also watched with some concern as the usage 

 and the threats to the environmental quality of the Bank have multiplied. 



The threats are real. The Department of the Interior has identified 

 Stellwagen Bank as a prospective area for sand and gravel mining (Pat 

 Hughes, MCZM, in Proceedings of the 1990 Stellwagen Bank Conference). 

 Many of us were initially amused when Richard Gugel proposed building an 

 artificial island casino on Stellwagen Bank in 1987, until we discovered 

 that his proposal was being seriously considered by the Army Corps of 

 Engineers. Plans for Boston's Third Central Artery Tunnel and the deepening 

 of Boston's inner harbor in 1995 could result in the dumping of contaminated 



dredge spoils in the midst of one of the most productive fisheries areas in 

 Massachusetts waters. In the five counties that border the coastline of 

 Massachusetts, the population increased by almost 133,000 between 1971 and 

 1988 (U.S.Dept.of Commerce, Bureau of the Census, Northeast 1988 population 

 estimates for counties and incorporated places, March 1990). Problems 

 regarding sewage disposal and associated marine pollution related to this 

 population growth are very real indeed. 



The biological, esthetic, and economic importance of Stellwagen Bank as Pag© G51 



defined under Title III make it a prime candidate for sanctuary status, as => 



does its need for protection and coordinated, multiple-use managsseat. 



However, effective multiple-use management of an offshore area such as 



Stellwagen requires careful and detailed planning. While NOA.* has succeeded 



in producing an admirable document in the DEIS/MP for Stellwagen, we would 



like to suggest some areas of concern for which additional consideration may 



be required. 



