Massachusetts Wildlile Federation 



The Slate Affiliate of 

 Nation al Wildlife Federation 



71 Cliff Road 



Uiellesley Hills, MR 02181 



10 Maixh 1991 



1 



c2 



Joseph fl. Urauitch, Chief 



Sanctuaries and Reserues Diuision 



Office of Ocean and Coastal Resource Management 



National Ocean Serulce/NOflfl 



1825 Connecticut fluenue, NU), Suite 714 



lUashington, DC 20235 



Subject:Stellujagen Bank National Marine Sanctuary/ Draft EIS/MgtPlan 

 Dear Mr. Urauitch: 



The Massachusetts lUildlife Federation, Inc., the state affiliate of 

 National Ulildlife Federation, heartily endorses the concept of The 

 Stelliuagen Bank National Marine Sanctuary. Homeuer, we offer the 

 comments beloo* on the subject Draft EIS/MP dated January 1991. 



Discrepancies eHist betuieen the Prohibited/Subject-to-Regulation 

 flctiuities on p2 (EHecutiue Summary), plQ2-103 (Draft Mgt plan), pl85 

 (Designation Document), and pl94-l95 (Proposed Amendment to 15 CFR 

 Chapter IH). 



Since the Rmendment to 15 CFR mill be the end result of the sanctuary 

 designation process, I will comment only upon that document. 



§ 940.2 Boundaries 



In place of NORR preferred altematiue #2 described on page 129-130, 

 MUJF recommends that the Sanctuary be defined by Loran C Coordinates 

 13750, 13870, 44140, 44295 and their Latitude/Longitude equiualents. 



These coordinates outline an area just slightly larger than the NORR 

 preferred one, but has the aduantage that all of the Mass Bag Disposal 

 Site mould be in the sanctuary and hence subject to direct sanctuary 

 control. The Loran Coordinates mould allom any uessel to easily deter- 

 mine the sanctuary boundaries. ( See attached sketch.) 



"flithough the Draft EIS/MP(pl86) states that Management of the 

 Fisheries mithin the sanctuary remain the prouince of the NEFMC, the 

 proposed amended §940 does not address this Issue. Therefore, me rec- 

 ommend thot a section be included in §940 to state: 

 Fishing RegulatJons, licenses and PermHs. Fishing in the Sanctuary, in- 

 cluding fishing for shellfish and inuertebrates, shall not be regulated as 

 part of the Sanctuary management regime authorized by the Ret. 

 Homeuer, fishing In the Sanctuary mag be regulated other than under 

 the Ret by Federal and Stole authorities of competent Jurisdiction, and 

 designation of the Sanctuary shall haue no effect on any regulation, 

 permit or license issued thereunder.e.g. regulations implementing 

 Fishery Management Plans promulgated under the Magnuson Fishery 

 Conseruation and Management Ret, 16 U.S.C. 1801 et seg. 



MASSACHUSETTS WILDLIFE FEDERATION 



1. No response necessary. 



2. See generic responses B.l. and B. 



3. See generic response N. 



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