//, 



Manageme nt Issues 



12- 



(3. 



/^ 



Manapement/Budget : Given the location and current high level of use of the 

 Stellwagen Bank area by both tourists and residents, the Coaliti on strongly urges that 

 management alternative #3 be implemented. This plan ensures rapid implementation of 

 the sanctuary program in the Stellwagen Bank area through the full funding, full staffing 

 and establishment of local sanctuary headquarters as well as two "satellite" information 

 centers. 



Staff should include at a minimum a sanctuary manager, a research coordinator, 

 an educational coordinator, two or more enforcement officers, one staff member for each 

 satellite office, and a seaetary. Additional funding should be added to the educational 

 program and to the manager's fund to assist in the management and educational 

 programs at the satellite offices. The budget of $570,000 proposed in the prospectus 

 accompanying the DEIS/NfP would not allow for full staffing or adequate managenient, 

 educational, and research programs. Proper funding is essential if the program is to 

 fulfill its congressional mandate to provide long-term, comprehensive protection to the 

 nationally significant marine treasures of this region. 



Education: Ultimately, the protection of the Stellwagen Bank area's rich natural 

 heritage will depend on a knowledgeable and caring public made up of both residents 



and visitors alike Thus, the SBNMS educational component is very important TTie 

 ^ctS pro^ is unique in its ability to promote a natiotul -«i/=^°-i-^* ^^^^ 

 local ed^<^tio^ settings In addition to promoting respect for ^"^^^ "^3'^^P°f 

 our marine heritage, we encourage the SBNMS program to develop ^dutiUze 

 educational materials that draw clear connections between resource values and any 

 regulations developed to enhance resource protection. 



r Research: Regarding research activities, emphasis should be placed on 'applied" 



researc^Sd at monitoring long term environmental trends cuinulanve "TiP^^s and 

 remedial measures for any problems THese problems include the affects of re^eational 

 ^d commercial traffic, thVoutfall mmiel and the MBDS. To the «=«"\^='' '^,=^^ ="^^' 

 but have yet to be put to use in addressing problems, the sanctuary program could serve 

 as an important vehicle for linking researchers with deas.on makers and managers. 



^ AHvisnrv rnmmittee: We endorse NOAA's proposal to establish a "fonnal 



sanctuary advisory comiruttee" (SAC) which can serve to assist mterested groups in 

 p^cipiing in Se sancmary program, as well as for the Stellwagen Bank areas and 

 advise NOAA on a range of issues affecting sanctuary management, educauon and 

 research This committee, made up of individuals in support of the sanctuary, should be 

 strictly advisory in nature, with NOAA retaining full responsibility for the admimstration 

 and management of the sanctuary and its resources. Moreover, a full range o 

 perspectives, expertise, and experience should be represented. Given ^e high level of 

 Lt^est and support this effort has received from the Stellwagen Bank Coalmon and its 

 vigorous participation in the designation process, we feel that it would be only proper 

 that members of the Coalition which include members of the fishing, academic and 

 research communities be thoroughly represented on the committee. 



Other Isinies 



We have identified several inconsistences in the DEIS/MP. These inconsistencies 

 send an unclear message in several of your recommendations. For example, on page i 

 and 102 of the DEIS/MP NOAA proposes the prohibition of the mstallaoon of pipelmes 

 and cables within the sanctuary. Yet on page 2 and page 195 and other areas of the 

 document this prohibition is not included. Although NOAA may assume that thjs 

 prohibition is implied in several of the other prohibitions, it is not clear. The Coalmon 

 supports this prohibition and recommends that NOAA clarify its recommendauons. 



' In the abstract and page 10 the DEIS/MP states that the principal humari activity 



dependent on the Bank's resources is commercial fishing. According to several studie 

 including information collected from the Stellwagen Bank Conference whale watching is 

 also a major activity both monetarily and as a user of the area. This activity also 

 enhances education of the areas resources. The Coalition recommends that whale 

 watching be included in discussions about the principal human activities dependent on 

 the Bank's resources (i.e. page 1). 



i^r Landings data and general information on the fisheries are poor. We find the 



'/ 1 description of fishing gear on pages 62-63 to be technically mcorrect. 



The Stellwticen Bank Coalition hopes that you u-ill find these comments and 

 suggest^r^ ulS^'we look to NOAA to be respor^ive to P^bic c°mmen, in prepan 



l^mbS S:-:^^^^=^^ J:Sif tr^r;"^arkable regio^n with 

 the long-lasting protection it so richly deserves. 



Please keep us fully apprised of the status of this proposal. 



15. 



IL 



11. At the time of final Sanctuary 

 designation, NOAA intends to have hired 

 a Sanctuary Manager, and to have identi- 

 fied a Sanctuary headquarters. Shortly 

 following, NOAA anticipates the hiring 

 of additional Sanctuary staff, including 

 a research coordinator, an education 

 coordinator, and one or more enforcement 

 officers. Congress has directed NOAA to 

 consider estahlishment of a "satellite" 

 office in Provincetown, Gloucester or 

 Hull, MA. 



12. NOAA agrees that development of an 

 effective Sanctuary education/inter- 

 pretation program is vital to the 

 accomplishment of Sanctuary objectives. 



13. A Sanctuary research plan will be 

 developed annually, including short- and 

 long-term projects addressing topics 

 necessary to improved resource protec- 

 tion and management. Such topics may 

 include assessment of the effects of 

 recreational and commercial vessel 

 traffic, or the effects of the MWRA 

 outfall pipe, or the MBDS. 



14. See generic response 0. 



15. Inconsistencies related to the 

 proposed prohibition on installation of 

 pipelines and cables within Sanctuary 

 boundaries have been clarified. 



16. Whalewatching has been added to dis- 

 cussion in the Abstract and PART ONE, F. 

 (Purpose and Need for Action) . 



17. Data on fisheries landings and on 

 fishing gear have been updated and 

 revised (see PART TWO, Section II.C.l.) 



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