Sancfjaries and Reserves Division 



Office of Ocean and Coastal Resource Management 



National Ocean Service/NOAA 



13;5 Connecticut Ave. NW 



Suite 714 



Wasnmgton, DC 20235 



March 25, 1991 

 Gtv of Bosion 

 The Environmeni Attn: Mr. Joseph A. Uravitch, Chief 



Dcpinmcnt gg . stellwagen" Bank .Mational Marine Sanctuary DEIS/.tP 



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Mjvof Ds^r ^^ • Uravitch: 



Lorrj.nt M. Dovvncv The City of Boston Environment Department has reviewed the 

 Dircc:or Stellwaae-. Bann Draft Environmental Impact Statement and 

 Master Plan and hereoy submits tne following comments 

 pertaining t.hereto: 



Bo»iun Tin HllLRoum 8ni 



7. 



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The environmental resources of Stellwacen Bank have lone 

 contributed to biological richness and diversity in tne 

 southern portion of the Gulf of Maine, and this valuaole 

 area has in turn both supported the regional economy and 

 instilled an aporeciation of Che natural heritage of the 

 ocean into the people of New England. 



Althouoh the existing regulatory framework provides seme 

 protection for t.his precious natural resource, the 

 designation and diligent implementation of a Sanctuary will 

 allow the corprehensive and well-integrated management 

 necessary to protect tne area from the ever-increasing 

 pressures which now threaten it. 



In general, the DEIS/.M? adequately establishes the framework 

 for successful husbandry of this resource area. However, 

 there are some issues which should be more fully discussed 

 in the FEIS/M?. 



Efforts to clean up the polluted Boston Harbor environment 

 must be given a high priority. One key portion of the 

 harbor cleanup effort is the construction of the 

 Massachusetts Water Resource Authority's Deer Island 

 Wastewater Treatment Facility. The outfall for this 

 important facility will be located approximately 23 k:n from 

 the Stellwagen Study Area. The DEIS/.^ i.mplies agree.T.ent 

 with the Deer Island EIR/EIS conclusion that "a 

 ciff user-type outfall located in the [general Stellwagen] 

 area... would be environmentally acceptable" (DEIS/M? p. 85). 

 Given the demonstrated importance of the Deer Island 

 facility to improved conditions in Boston Harbor, 



the FEIS/MP should state explicitly that the creation of the 

 Stellwagen Sanctuary in no way conflicts with construction, 

 operation, and/or maintenance of the outfall planned by 

 MWRA. The City of Boston's enthusiasm for the creation a 

 the Sanctuary is conditional upon its full compatibility 

 with the cleanup of Boston Harbor. Protection of one area 

 must not interfere with restoration of another. 



The question of boundary alternatives should be more fully 

 discussed in the FEIS/MP. NOAA has stated a preference for 

 boundary alternative (2, but does not provide enough 

 information on the relative environmental impacts of 

 choosing these boundaries over those delineated in 

 alternative 13. NOAA does express interest in coordinating 

 management of the general area with the Commonwealth of 

 Massachusetts; alternative #3 would seem to allow the 

 greatest degree of coordination since it would create both a 

 northern and southern boundary with waters under the 

 jurisdiction of the Commonwealth. 



CITY OF BOSTON 



The Environment Department 



1. No response necessary. 



2. Designation of the Sanctuary will 

 have no direct effect on the construc- 

 tion, operation, and/or maintenance of 

 the MWRA diffuser-type outfall for 

 municipal waste materials. The MWRA has 

 suggested that adverse impacts on Sanc- 

 tuary resources resulting from the 

 outfall are extremely unlikely, given in 

 particular the distance from the outfall 

 to the Sanctuary boundary. In general, 

 however, NOAA has proposed a prohibition 

 on discharges into the Sanctuary, or on 

 discharges from outside the Sanctuary 

 which enter the Sanctuary and cause harm 

 to Sanctuary resources or qualities. In 

 the unlikely event of discharges from 

 the MWRA outfall entering the Sanctuary 

 and causing such adverse impacts on 

 resources or qualities, NOAA maintains 

 the authority to impose additional con- 

 ditions on outfall activity, or to stop 

 the outfall activity altogether. 



3. See generic response B.l. 



Alternative #3 would include the Massachusetts Bay Di 

 Site within its boundaries, but as stated in the DEIS 

 granting of an exemption to the prohibition of dumpin 

 this portion of the Sanctuary would be consistent wit 

 policies in Sanctuary areas already in existence. In 

 of this site within the Sanctuary boundaries would al 

 NOAA an more prominent position in managing disposal 

 dredged materials in the area, thereby affording extr 

 insurance that the site will be operated in an 

 environmentally sensitive manner. 



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