buffer zones replace the fences used in traditional land management 

 techniques. This approach requires a greater area to protect a given 

 resource than would nonnally be necessary on land. NOAA believes, however, 

 that after analyses of potential impacts on the total human environment, 

 5 sq nm represents a reasonable buffer beyond that provided through the 

 HAPC. This in combination with the management oriented facets of the 

 sanctuary program will complement the efforts of the Councils to protect 

 coral species in the fishery conservation zone. 



Second, the Council's FMP limits the definition of coral reef 

 resources to the actual coral structure. This leaves the majority 

 of invertebrates and lower vertebrates without specific protection. 

 The productivity of coral reefs, equalled only by that of tropical 

 rain forests, is a result of the organisms forming the reef structure 

 (algal biomass may be three times greater than that of the corals); and 

 light, oxygen and efficient nutrient recycling as a result of the 

 innumerable non-coral reef organisms. It is this entire specialized 

 ecosystem that is the focus of sanctuary integrated research, education 

 and regulation over the long-term. 



In conclusion, the major differences between the proposed management 

 measures for the HAPC and the final proposed marine sanctuary regulations 

 are focused on the emphasis placed on comprehensive management, monitoring, 

 research and public education by the sanctuary program which is lacking 

 in the HAPC proposal and which complements the Councils' FMP efforts. 

 A comparison of the two programs was forwarded by the GMFMC and an updated 

 version is presented below. 



i 



E-3 



