Final environmental impact statement/management plan Cordell Bank National Marine Sanctuary

[From the U.S. Government Printing Office, www.gpo.gov]

Cordell Bank National Marine Sanctuary
Final Environmental Impact Statement/Management Plan

VolumeTwo

COASTAL ZONE

INFORMATION CENTER

U.S. Department of Commerce
National Oceanic and Atmospheric Administration
Marine and Estuarine Management Division

VOLUME TWO

FINAL ENVIRONMENTAL IMPACT STATEMENT
Prepared on the Proposed
Cordell Bank National Marine Sanctuary

April 1989

U.S. Department of Comerce
National Oceanic and Atmospheric
Administration
Office of Ocean and Coastal Resource
Managment
Marine and Estuarine Management
Division I
1825 Connecticut Ave., N.W. Suite 714
Washington D.C. 20235

Property of CSC Library
US Department of Commerce
NOAA Coastal Service Center Library
2234 South Hobson Avenue
Charleston, SC 29405-2413

This Volume includes the comnents received on the Draft Environmental

Impact Statement/Management Plan (DEIS/MP) prepared on the proposed Cordell

Bank National Marine Sanctuary, and provides the National Oceanographic and

Atmospheric Administration's (NOAA) responses to these camients. Generally,

the responses to comwnts are provided in one or a combination of forms:

1. E>qDansion, clarification or revision of the DEIS/MP,

2. Generic Responses to comTients raised by several

reviewers, and/or

3. Brief responses to detailed conmients received from each

reviewer.

Written comTents from individuals, organizations, State and local

governments and Federal, State and local agencies are printed verbatim, and

verbal comTents, received at public hearings, have been summarized at the end

of this volume.

Generally, the comments are printed on the left side of the page and

NOAA's response is on the right side of the page. Comments requiring no

response are printed on the right side of the page.

Ten general issues were raised frequently by reviewers of the DEIS/MP.

The responses to these issues are presented below. Commenters will be

referred to these generic responses in the text.

GENERIC OOMMENTS

GENERIC COMMENT A:
The majority of coomenters re=mnended the selection of boundary
alternative #1, the largest boundary option (397.05 square nautical miles).
It was felt that this larger boundary would protect a greater area of
ecological significance and facilitate management and protection of the
Sanctuary.

GENERIC RESPONSE A:
NOAA has adopted this recomendation. The larger boundary enconpasses
additional habitat utilized by marine mamTals, seabirds for resting, feeding
and migration. In addition, it provides a larger ecological buffer area for
the unique concentration of resources found on and around Cordell Bank. The
larger boundary also provides for a more easily managed area as it is
contiguous to the Point Reyes-Farallon Islands National Marine Sanctuary.

The benthic resources, marine nk-mmls and seabirds that are observed on
and around Cordell Bank and on the adjacent continental shelf break were
described in the DEIS/MP. The distribution of these organisms in the area
surrounding the Bank provided the rationale for boundary alternative #2, a
101.10 square nautical mile area. However, information provided to NOAA
during the DEIS/MP conmient period and the results of recent research,
sponsored by the Point Reyes-Farallon Islands National Marine Sanctuary,
demonstrates substantial use by seabirds and marine rwmials of the area
encompassed by boundary alternative #1.

GENERIC COMMENT B:
A great majority of conmenters expressed their support for a Sanctuary
regulation prohibiting all hydrocarbon exploration and developuent activities
within the boundary of the Sanctuary frorn the time of designation.

GENERIC RESPONSE B:
NOAA does not intend to prohibit hydrocarbon activities at this time.
The Department of Interior's Outer Continental Shelf (OCS) Oil & Gas 5-Year
Leasing Plan, the proposed Sanctuary regulatory and management framework, and
existing Federal statutes presently provide adequate protection to the
Sanctuary's resources.

The current OCS Oil & Gas 5-Year Leasing Plan excludes Cordell Bank
within the 50 fathom. contour. Thus, the core area of the Sanctuary is
presently protected from hydrocarbon activities.

If areas within the Sanctuary are leased for hydrocarbon activities in
the future, NOAA has authority to certify and condition or deny certification
for, as necessary, permits or other authorizations granted to operators
(lessees or contractors) by other authorities for activities within the
Sanctuary which are otherwise prohibited. Such conditions may include, but
are not limited to, the establishment of a monitoring program and scientific
research studies to measure the effects of hydrocarbon activities on Sanctuary
resources and the restriction of discharges. Any conditions imposed by NOAA
on other authorities' permits will be made in consultation with those
agencies and the permitees.

The existing Federal regulations provide additional protection to
Cordell Bank. Environmental review and the opportunity for the public comment
take place prior to any hydrocarbon production according to the provisions of
the Outer Continental Shelf lands Act and the National Environmental Policy
Act. Further, OCS activities are 5ub3ect to the provisions of the Endangered
Species Act and the Marine Mammal Protection Act, which protect specific
organisms.

Finally,-NOAA has the ability to enact emergency regulations to prohibit
hydrocarbon activities, or any other activities, in the Sanctuary to prevent
imnediate, serious and irreversible damage to a Sanctuary resource. Such
emergency regulations shall remain in effect for no more than 120 days, during
which time permanent regulations may be proposed by NOAA.

GENERIC COMMENT C:
Several ccnmr-ntors recomDended that a proposed sewage outfall pipe fraL
the City of Santa Rosa be prohibited as it was believed that discharges from
the cutfall could possibly impact the Sanctuary.

GENERIC RESPONSE C:
The City of Santa Rosa is considering several sites for the disposal of
sewage effluent. Any sewage discharges would have to be permitted by the
Environmental Protection Agency through the regulations which inplement
Section 402 of the Clean Water Act. In addition, under Sanctuary regulations,
NOAA raust certify permits from other authorities for activities which are
prohibited by Sanctuary regulations and can require additional conditions (or
deny certification) if necessary to protect Sanctuary resources. one
potential site to the north of Bodega Head would be outside of the boundary of
the proposed Sanctuary. However, discharges from such an outfall, which enter
the Sanctuary and injure its resources, are prohibited under Sanctuary
regulations.

The plans of the City of Santa Rosa for a sewage outfall pipe are still
in the preliminary stages and the eventual disposal site and the nature of any
discharges remain undecided. NOAA, as manager of the Point-Reyes Farallon
Islands National Marine Sanctuary, is a menber of the task force set up by the
California Regional Water Control Board, to determine the optimal site and
nature of the discharges.

GENERIC COMMENr D:
Many camientors reconffended that anchoring on the ridges and peaks of
Cordell Bank be banned to prevent damage to benthic organisms.

GENERIC RESPONSE D:
Anchoring on the Bank can injure or destroy the benthic organisms by
physical irpact and by dragging of the anchor chain. NQAA recognizes that
this activity could have a significant effect on the benthic flora and fauna
and should be carefully monitored. However, at present few vessels visit
Cordell Bank and anchor on it.

However, regulation of anchoring has been added to the scope of potential
regulations in the Designation Docment (Article 4) and will be considered if
anchoring activities increase and threaten the Bank's resources. This
potential regulation would only apply to Cordell Bank and the area within the
50 fathcxn contour surrounding Cordell Bank.

GENERIC COMMENT E:
Some commenters were unclear as to whether the Sanctuary's regulations
would apply only within the 50 fathorn isobath surrounding Cordell Bank or
throughout the entire Sanctuary. One comTenter felt that all regulations
should apply only within the 50 fathom isobath.

GENERIC RESPONSE E:
Article 4 of the Sanctuary Designation Document has been modified to
eliminate arbiguities concerning the application of the Sanctuary's regulatory
program. Five activities are potentially subject to regulation by designation
of Cordell Bank as a National Marine Sanctuary. These include: depositing or
discharging of materials or substances; removing, taking, or injuring or
atteaTpting to remove, take or injure benthic invertebrates or algae;
hydrocarbon activities; anchoring; and removing, taking, or injuring or
attempting to remove, take or injure historical or cultural resources.

At the time of designation, only the deposit or discharge of materials or
substances, and removing, taking, or injuring or attenpting to remove, take or
injure benthic invertebrates or algae will be regulated. The prohibition
against depositing or discharging will apply throughout the Sanctuary. In
addition, such discharges beyond the boundary of the Sanctuary which enter the
Sanctuary and injure its resources are prohibited. Prohibition of discharges
or deposits beyond the 50 fathom isobath is necessary to protect those
pelagic or migratory resources (including seabirds and marine mamwals) which
occur throughout the Sanctuary.

The prohibition against the taking of benthic invertebrates or algae
shall apply only to the immediate vicinity of the Bank; within the 50 fathom
isobath. Prohibition within this discrete area is deemed sufficient to
protect the Bank's unique benthic resources found on the submerged seamount.
This regulation does not restrict com-parcial or recreational fishing
activities. The accidental taking of invertebrates or algae during normal
fishing operations would not be in violation of this prohibition.

If it is necessary to prohibit hydrocarbon activities in the future to
protect the Sanctuary's resources, this restriction will apply throughout the
Sanctuary. The potential damage to resources from hydrocarbon activities
would extend to those pelagic and migratory resources occurring on and beyond
the Bank itself. Any hydrocarbon exploration or development activity will be
monitored to determine the effect on Sanctuary resources.

If it is necessary to regulate anchoring in the future to prevent damage
to the Bank's resources because of increased use, such regulation will apply
to Cordell Bank and the area within the 50 fathom isobath surrounding Cordell
Bank. It is in this area where the benthic resources are most concentrated
and potentially susceptible to anchor damage.

If it is necessary to regulate the taking of historical or cultural
resources, such a prohibition will apply throughout the Sanctuary.

GENERIC COMMENT F:
A ccmmntor stated that the regulation prohibiting discharge and deposit
of material in the Sanctuary was an unnecessary layer of additional regulation
onto existing ones. It was stated that with the exception of solid wastes the
discharge of materials or substances was covered by existing laws and
regulations.

GENERIC RESPONSE F:
The regulation prohibiting discharges and deposits within the Sanctuary
couplements the existing regulatory system, enhances the area's overall
recreational and aesthetic appeal, and helpsrnaintain the present water
quality in the Sanctuary. Numerous laws and regulations apply to the disposal
of waste in the marine environment. However, most,decisions are made on a
case-by-case basis, which provides less certainty of protection than would the
designation of a no discharge area which protects the complete Sanctuary
habitat.

The CWA provides for a maximum penalty of $10,000 for a single discharge
incident without the initiation of a civil action. This does not provide
sufficient deterrent for protecting inportant Sanctuary resources; $50,000 is
the maximum penalty allowed under Sanctuary regulations.

Certain gaps exist in the regulatory framework. The discharge of oil
and other hazardous substances in the territorial sea is subject to
Environmental Protection Agency (EPA) requirements under the Clean Water Act
(CWA) and U.S. Army Corps of Engineers (ODE) requirements under the Rivers and
Harbors Act (for discharges that might obstruct navigation). These statutes
are designed to protect marine resources, but do not generally provide for
ccuprehensive protection of a marine area and do not specifically prevent
certain activities that ray harm the resources of the Sanctuary, such as
overboard disposal of trash from ships.

Beyond the territorial sea, EPA approval is needed for ocean dumping and
for any location of a new ocean outfall. EPA regulations take the ecological
productivity and sensitivity of an area into consideration. However, such
regulations to not guarantee that EPA will prohibit the disposal of waste in
the Sanctuary. Specifically, the provisions of the CMA do not apply to
discharges of non-biodegradable solid wastes as casual litter. The
Sanctuary's prohibition is designed specifically to protect the area's
important living resources from the effects of all harmful effluent and solid
wastes and to facilitate the recovery of damages caused by discharges which
injure those resources. In addition, it prevents floating or submerged waste
debris (e.g., non-biodegr-adable plastics) from being deposited in areas where
animals could eat or become entangled in the debris, possibly leading to
illness or death. Finally, the deposit of non-biodegradable litter reduces
the aesthetic qualities of the Bank and thereby detracts from its recreational
value.

GTNERIC CCMMERr G:
Concern was expressed that the DEIS/MP Santuary proposal does not
provide enough personnel, equipment and financial resources, for comprehensive
management of the Cordell Bank National Marine Sanctuary. It was stated that
there should be an increase in staff and funding with recomw-ndations for a
Sanctuary Headquarters office at Bodega Bay or Point Reyes. This proposed
Headquarters should also include increased enforcement capability and an oil-
spill recovery unit. An increase in management personnel was also believed
necessary to conduct long-term monitoring, research and surveillance and
enforcement activities.

GENERIC RESPONSE G:
Projected staff, equipment and facilities needs, described in the
DEIS/MP, are believed to be sufficient to meet existing Sanctuary managemient
needs. The budget for Sanctuary management will be based on available
resources and more solid assessments of monitoring requirements. The Point
Reyes-Farallon Islands National Marine Sanctuary management staff will
continue to use its patrol-vessel for resource protection in the Cordell Bank
National Marine Sanctuary. Resource protection, as described in the DEIS/MP,
will include coverage by Sanctuary wardens who will expand their present
coverage of the The Point Reyes-Farallon Islands National Marine Sanctuary to
include Cordell Bank. In addition, the routine air and sea patrols of the
United States Coast Guard and the California Department of Fish and Game will
assist with surveillance and enforcement activities.

Any necessary oil-clean up activities are managed by the United States
Coast Guard, which directs the National Response Team under guidance provided
by the National Contingency Plan. Oil spill clean-up and recovery equipment
includes that of an oil industry consortium, "Clean Bay", and U.S. Navy oil
I'skinmer" vessels based in San Francisco. The San Francisco Bay area
presently requires this equipment to respond to emergencies there. However if
hydrocarbon development does occur in or around the Sanctuary it is likely
that the oil industry will station oil spill clean-up equipment in the Bodega.
Bay area.

GENERIC CONMENT H:
NOAA should consider provisions to increase shipping safety in the area.
Such plans should include deployment of special buoys, communication systems
and redirection of vessel traffic to prevent collisions and possible spills of
hazardous materials.

GENERIC RESPONSE H:
NOAA agrees that it is preferable to prevent vessel accidents as well as
prepare contingency and emergency plans in case of vessel collisions and
accidental discharrjes. NOAA has determined that existing shippuig safety
regulations are adequate and that no further action is necessary. The United
States Coast Guard (USCG) has jurisdiction over shipping safety in U.S. waters
and NOAA has kept in close communication with this agency regarding shipping
safety. r1he USCG has determined that the existing regulations and Traffic
Separation Scheme (TSS) are adequate for the number of vessels using the San
Francisco Bay port approaches in the area around Cordell Bank. This
determination is based on a completed Port Access Route Study and an
estimation by the USOG, that although compliance is voluntary, virtually all
traffic complies with the TSS.

The Coast Guard has also initiated the Offshore Vessel Movement Reporting
System (OVRAS), an advisory service to inform mariners of the location and
movements of large vessels, such as oil tankers, in the ocean approaches to
San Francisco Bay, including areas east of Cordell Bank. Participation by
mariners is voluntary but by monitoring the radio transmissions of vessels,
close encounters and possible collisions between ships may be avoided. NOAA
will continue to cooperate with the Coast Guard in enforcement and
surveillance procedures that relate to shipping within Sanctuary waters.

It is irportant to note that under International Law, foreign flag
vessels in waters beyond the limits of the U.S. territorial sea, such as
around Cordell Bank, cannot be regulated directly by NOAA or the USCG. Under
international law, any regulation of navigation on the high seas must be
endorsed by the International Maritime Organization in order for it to
apply to foreign flag traffic. Finally, the National Marine Sanctuary Program
has prepared a National Computerized Contingency and Emergency Response Plan,
which can focus on individual Sanctuaries such as Cordell Bank. 'Ihe plan
details alert procedures and responses and describes Sanctuary resources at
risk. The plan will be expanded to include Cordell Bank.

GENERIC CaUENT I:
There was disagreement on the need and extent of possible regulation of
fishing activities. There were statzmvents made that overfishing had already
occurred and that "abnormal" fishing activities should be banned. In
contrast, NOAA also received comments that asked for confirmation that
commercial and recreational fishing will be excluded from the scope of
Sanctuary regulations.

GENERIC RESPONSE I:
NOAA reaffirms that no regulation of fishing, other than by existing
State and Federal statutes, will occur with the designation of the Cordell
Bank as a National Marine Sanctuary. Fishing vessels, however, mLst comply
with the Sanctuary's regulatory prohibition on discharges. All State and
Federal regulatory programs pertain to fishing, including Fishery Management
Plans promulgated under the Magnuson Fishery Conservation and Management Act,
will remain in effect.

Sanctuary wardens will enforce the California Department of Fish and Game
Code (and Chapter 14 of the California Administrative Code), which regulates
and manages a wide variety of activities affecting the living marine resources
found in the territorial sea and in the 200-mile wide exclusive economic zone.
In addition, NOAA will continue to monitor the status of fishery resources
around Cordell Bank.

GENERIC COMMENT J:
Comments were received that requested NOAA protect any historical or
cultural artifacts that my be found within the Sanctuary.

GENERIC RESPONSE J:
NOAA agrees that it is necessary to protect and manage any historical and
cultural artifacts that may be in the Sanctuary. At present, NOAA is unaware
of any historical or cultural resources on Cordell Bank. NOAA recognizes that
the lack of information does not mean that such resources are not present.
Therefore, a prohibition on the removing, taking, or injuring or attempting to
remove, take or injure cultural or historical resources has been added to the
scope of activities potentially subject to regulation.

INDIVIDUAL COMMENM

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page I of 2

8 October 1987

Re: CORDELL BANK

Ms. Vickie Allin, Acting Chief
Marine and Estuarine Management Division
Office of Ocean and Coastal Management
National Ocean Service, NOAA
1825 Connecticut Avenue,N.W.
Washington, D.C.. 20235

Dear Ms Allin
1. See Generic ReSPCnse A.
I write to you on the subject of the draft environmental impact
statement, draft management plan, and proposed rule for 2. See Generic ReSPCrLse B.
the Cordell Bank National Marine Sanctuary. Cordell Bank is an
undersa elevation which, be@ause of a combination of oceanic
conditions and undersea topography provides a biologically rich
area with clearly defined boundaries. Adding to these qualities, the
upwelling currents, and the Western Coast has a very special place
which supports a wide variety of sea birds, fish, and marine
mammals, as well as almost 300 identified types of plants.
l
Of the alternatives available, I firmly support Alternaive # 2;
boundary alternative # 2, to designate this sanctuary and its
vulnerable marine situation.

it course' f crucial importance that oil and gas
exp'l'o'raotfion and de'velopment be prohibited in this sanctuary.
I plead with you and the Office @f Ocean and Coastal Management
to take advantage of this marvelous opportunity to protect the
Cordell Bank as a Marine Sanctuary.

Sincerely and r ectfull

Anne Baeck
441 Boynton Avenue
Berkeley, CA. 94707 ra
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page 2 of 2

CC:

Mr. Edward Wilczynski, Acting Chief
Ecology and Conservation Division, Room 6814
U.S. Department of Commerce
Washington, D.C. 20230

The Honorable C. William Verity.Jr.
Secretary of Commerce
U.S.Department of Commerce
Washington, D.C. 20230

Senator Alan Cranston
Senate Office Building
Washington, D.C.,20510

Senator Pete Wilson
Senate Office Building
Washington, D.C., 20510

Congressman Ronald Dellums
House Office Building
Washington, D.C., 20515

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October 07, 1987

Ms. Vickie Allin
1825 Connecticut Ave.
Washington D.C. 20235

Dear Ms. Allin,

I further support both the formation of BOUNDARY #1 in hopes of proid-
ing the broadest area of protection, and a ban on all offshore oil
drilling activity including leasing, exploration and developement
thin the Cordell Bank Marine Sanctuary.

Sincerely,

Janice A Banta
Larkspur, CA

October 5, 1987

Vickie Allin

Marine and Estuarine Management Division
OCRM, National Ocean Service/NOAA
1825 Connecticut Avenue, N.W.

Washington, D.C. 20235

Dear Vickie:

I support the proposed Cordell Bank National Marine
Sanctuary. Please help support it.

Please support "Boundary Alternative #1" to give 1. See Generic Response A.
the broadest area of protection.

Please ban OCS oil and gas leasing, exploration
and development for the Cordell Bank area and 2. See Generic Response B.
all of our coastal areas.

Thank you for your help and support in protecting
and preserving our beautiful natural resources.

Sincerely,

12 13 1.

Harve Bell, Jr. N
(a
700 Lindsay Avenue U) OCT 3
Rohnert Park, CA 94928 CA
Ha ve . @Belljr.

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Lisa Brown
1016 3rd St #3
Novato, Ca. 94945

October 07, 1987

Ms. Vickie Allin
1825 Connecticut Ave.
Washington D.C. 20235

Dear Ms. Allin,

I further support both the formation of BOUNDARY #1 in hopes of proid- 1. See Generic Response A.
ing the broadest area of protection, and a ban on all offshore oil
drilling activity including leasing, exploration and development 2. See Generic Response B.
ithin the Cordell Bank Marine Sanctuary.

Sincerely,

Lisa Brown
Novato, CA

1. See Generic Response A.

2. See Generic Response B.

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Ms. Allin,

I am writing this letter to you in regards to the designation of Cordell
Banks, CA, as a National Marine Sanctuary. I feel that it is imperative 1. See Generic Response A.
that the area boundary #1 be established for the protection of this very
unique and pristine area. I wish to express my adamant desire the the
entire area have a ban on all hydrocarbon activity. I cannot emphasize
enough the importance of the ban. One only needs to see some of the
photographs and video of the underwater area to see how fragile this area
is, and see how detrimental to the area that would be possible should 2. See Generic Response B.
Uh.drocarbon activity be allowed. I must insist that as a concerned American
citizen, this area receive the entire support you can give it in this
direction. I will do everything in my power to see that this area be
.Lrotected. A great number of my friends and relatives feel the same way.
e completely support the Area Designation Boundary No. (, and a ban
on all hydrocarbon activity, and further request that additional funds 3. See Generic Response G.
for on site monitoring, and that provisions for enforcing the regulations
e ammended to include a ban on all contact with the shallow ridges (such
as anchoring). We will do all that we can to fight for these recommendations
and additional funding as necessary to preserve this beautiful area. 4. See Generic Response D.
Thank you.

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San Francisco, Ca. 94122
October 7, 19871

Ms. Vicki Allin, Acting Chief
Marine & Esturine Management Division
Office of Ocean & Coastal Resource Mgmt.
National Ocean Service/NOAA
Washington D.C. 20235

Dear Ms. Allin,'

I am writing in response to the Draft EIS and Draft Designation
Document for the Cordell Bank National Marine Sanctuary proposal.
I am a wildlife biologist and have spent many years working and
recreating in the natural world. I am currently a wetland
specialist.
One of my most awesome experiences in-nature was a pelagic
trip I took out to the Cordell Banks to observe whales, seabirds
and other sea life. For hours we observed humpback whales feeding
on the rich Invertebrate life; we watched from a distance of
one hundred feet as a blue whale filtered these marine organisms
at the surface. This area is truely a national treasure which
should be protected. My observations of the huge impact and
encroachment human activity has on the natural environment in the
Bay Area if unchecked, show that these areas must be protected 1- see Generic ResPonse A.
by formal designation.
For this reason I strongly support the designation for a
0r de 11 Bank National Marine Sanctuary, specifically Alternative 2. See Generic Response B.
2 Boundary Alternative #2. 1 also urge the ban on offshore oil
and gas exploration and development be extended to the whole
@bodary of the Sanctuary.
Sincerely,
13&g2@_
Joelle Buffa

40 OCT@lw ev
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RECEIVED

October 9, 1987 Re: Cordell Bank draft EIS,
management plan, and rule
for Nat'l Marine Sanctuary
Ms. Vickie Allin
Acting Chief, Marine and Estuarine
management Division
Office of Ocean and Coastal Resource Management
National Ocean Service/NOAA
1825 Connecticut Avenue, N.W.
Washington, D.C. 20235

Dear Ms. Allin,

We strongly support the designation of Cordell Bank as a National
Marine Sanctuary, and urge the adoption of Boundary Alternative #2.

In order to protect the ecological and bio-economic values of
the area, we urge that strong prohibitions against oil and gas
exploration and development in the area be established as well.

Sincerely,

Robert D. and Judith S. Burness
Box 452
Inverness, CA 94937

1. See Generic Response A.

2. See Generic Response B.

cc: Edward Wilczynski, Dept. of Commerce
Sec. William Verity, Sec'y of Commerce
Senator Alan Cranston
Senator Pete Wilson
Representative Barbara Boxer

October 07, 1987

Ms. Vickie Allin
1825 Connecticut Ave.
Washington D.C. 20235

Dear Ms. Allin,

I would like to express and extend my support for the proposed creation
of the CORDELL BANK MARINE SANCTUARY. I am aware, as are many people,
of the devastating effects offshore oil drilling would have on the
marine life and enviornment.
[
Ifurther support both the formation of BOUNDARY #1 in hopes of proid- 1. See GeneriC Response A.
'g the broadest area of protection, and a ban on all offshore oil
dilling-activity including leasing, exploration and developement 2. See GerleriC Response B.
wi thin the Cordell Bank Marine Sanctuary.

Sincerely,
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October 07, 1987

Ms. Vickie Allin
1825 Connecticut Ave.
Washington D.C. 20235

Dear Ms. Allin,

Sincerely,

Robert C. Capurro
San Anselmo, CA

1. See Generic Response A.

2. See Generic Response B.

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October 07, 1987

Ms. Vickie Allin
1825 Connecticut Ave.
Washington D.C. 20235

Dear Ms. Allin,

I further support both the formation of BOUNDARY #1 in hopes of proid-
ing the broadest area of protection, and a ban on all offshore oil
dr000000 activity including leasing, exploration and developement
within the Cordell Bank Marine Sanctuary.

Sincerely,

Stephanie Coleman
San Rafael, CA

1. See Generic Response A.

2. See Generic Response B.

94 Crest Road
Novato, California 94945

Ms. Vickie Allin
Acting Chief, Marine and Estuarine Management Division
OCRM, National Ocean Service/NOAA
1825 Connecticut Avenue, N. W.
Washington, D. C. 20235

October 7, 1987

Dear Ms. Allin,

My colleague and I are writing to support the creation of a
Cordell Bank National Marine Sanctuary west of Pt. Reyes, California.
We include comments on the DEIS/Management Plan. We wish to
especially urge the creation of a Sanctuary based on BnundAz@z
Alt,-HVE _J, which exr-Iiides All nllshona hydancambiam ac.Usilties.
6
We were n ot able to at 'tend the hearings in California, but
would have presented the following information supporting our 1. See Generic Response A.
conclusion that Boundary Alternative . I provides a mlalmum large,
critical area of protection for the unique and endangered species of
Th i s unusual location, and that offshore oil and gas development- 2. see Generic Response B.
roelated activities should be,texcluded from within the Sanctuary
b unclaries. The "preferred a ernative" (Alternative 2) is not
"Tdequate to protect the resources -for which the Sanctuary is being
established, and offshore operations on or in the region adjacent to
the Bank would directly conflict with the Sanctuary's purpose.

One of the most compelling reasons for both the large size and
the oil exclusion requirements for an adequate Sanctuary, is the
remarkable habitat for great whales that appears to be provided by the
Bank and its vicinity. We are indeed fortunate that the Gulf of the
Farallons provides a protected area for these remnants of the great
whale populations. Cordell Bank is the prime spot for seeing Great
Blue Whales and Humpbacks. It is accessible by boat for viewing and
enjoyment and for scientific study. More importantly, it is an area
.where the animals can live safely, helping support any increase in
numbers that are necessary for these species to survive.

The DEIS/MP does not, in the few paragraphs of its information
about whales (pp.26-7), put their situation in perspective. From the
hundreds of thousands that may have once existed in the North Pacific,
population estimates now are a few thousand at most, for both the
Great Blue Whales and for the Humpbacks. But the numbers are not
certain. There may be as few as 1200 Blue Whales, 3000 Humpbacks. We
have@ no idea of the critical size or limited distribution patterns of
the populations beyond which they might not recover, making the
locations where they are known to be concentrated even more important.

Recent research indicates that we may have a resident summer
population of Great Blue Whales as well as Humpback Whales in the
vicinity of the Bank. Since this is an area where individuals have
been observed to feed (DEIS p. 26), and these whales are portions of a
depleted species, it would seem that Cordell Bank provides a critical
habitat area for these two endangered species.
3. It was our intention in the DEIS/MP to outline the value of all living
No information was provided as to great whale sightings in the resources in the vicinity of Cordell Bank. The species and patterns of fish,
vicinity of the Bank region, especially in the region between benthic organisms and sea birxds, (as well as whales), were described so that a
Head and the Bank. This information is needed to place the need for a reviewer of the DEIS/MP would gain a perspective of the biological diversity
larger protection area in perspective. and abundanoe of all natural resources
The DEIS, p. 65, takes a position against Boundary Alternative Marine mammals are a significant resource and NOAA recognizes the
I because "marine mammals are already protected under the provisions importance of detailed investigations into their abundance, distribution and
of the Marine Mammal Protection Act and there is no evidence that they behavior. Cordell Bank is especially important in this regard as a habitat
are particularly attracted to the entirety of this area any more than for marine mammals. NOAA is aware of the numerous sightings of marine
to other areas. There is, therefore, no need to protect all of these mammals in this area and how their abundance changes both annually and
waters as a habitat upon which marine mammals depend." It also states seasonally. However, many questions remain regarding individual behavior
on p. 70 regarding Alternative 2, "Because marine mammals are patterns and fine scale distribution patterns around Cordell Bank. NOAA,
attracted to Cordell Bank waters by the same food resources that through the Point Reyes-Farallon Islands National Marine Sanctuary, has
attract seabirds, it can be assumed that this alternative encompasses supported research over the past three years to investigate the distribution
the core area in which marine mammals feed." and abundance of humpback and blue whales as well as opportunistic sightings
of other marine mammals. Aerial and vessel-based survey methods were able to
However, actual research on these populations and their identify individual humpback whales. This research has provided a thorough
behaviors has only just begun, aimed primarily at the Humpbacks. Very baseline characterization and suggests that a local, "resident" population of
little is known about the needs and behavior of the Great Blue Whale. 88 humpback whales exists in the Point Reyes-Farallones National Marine
We know the whales do not stay just over the Bank, but can be seen Sanctuary and adjacent region.
elsewhere. Sightings from Oceanic Society vessels which one of us
reported in previous testimony placed great whales, including Blue
Whales, in the region between Bodega Head and Cordell Bank as well as 4. See Generic Response A.
in the vicinity of the Bank. The assumption of a 'core area' above
the Bank illustrates primarily our present lack of knowledge about the
importance of the surrounding region.

Moreover, the idea of protecting just a core area rejects the
ecological reality of the interconnectedness of oceanic systems. The
food resources on the Bank are dependent on the nutrients and clean
waters of the surrounding region. An oil spill, or the chronic
industrial pollution of nearby waters, will not respect the boundaries
of a 'core area'. For realistic protection, a large buffer zone is
needed which excludes as much of the possibility of oil development as
possible. The buffer should ideally be extended to the north 20 or 30
miles to provide a day or so of response time from spills in regions
that may be developed to the north.

The areas of oil leasing proposals in the vicinity are not 5. A map has been added that illustrates the extent of the area for potential oil
illustrated in the DEIS/MP, but should be. Although Cordell Bank is exploration and development activity. See Generic Response B.
adjacent from the current 5-year plan for offshore oil leasing, areas
adjacent to it are not. Some of this area, known to contain tracts of
high industry interest, would be protected from development under

Boundary Alternative 1.

The threat of spills from vessel traffic is already very real,
and many a+ the damages aLre visible and well-Ynown. The Sanctuary
should protect the resources from the less public additional threats
from offshore industrial development. Such development should
appropriately be precluded in this area, of biological treasures.

The more we learn of the impacts of offshore oil development,
from the initial seismic surveys, to exploration and development
discharges of drilling muds, formation waters, and other toxic
substances, to the small chronic spills and ever-present risl, of a
large spill , the more it seems wise to limit any development in the
vicinity of critical marine resources.
No mention is made in the discussion of hydrocarbon 6. The provisions of the Kuam lqammal anteution Act: of 1972 and the Endangered
development activies, pp. el-86, of the extensive seismic survey Species Act prohibit the taking of marine mammals ard erxiangered species,
operations that begin and accompany offshore exploration and resTecitively, with 1-ted exneption. 11akiM is defined tinder both acts to
development. Disruptive impacts of such surveys could occur to include harass-Tt. If seismic activities have no more than a negligible
Cordell Bank species, and to eggs and larvae in the planl1ton and other
organisms in the water column which provide food for the larger impact: on the species then taking Is Permtted under Section 101 (a) (5) of the
HMPA- 7he potential -pact of seismic surveys will be mcnitored by the
species in the Sanctuary area. Sancl:Uary staff to determine if the resources of sanatimay are jeopardized or
With respect to the discussion of drilling cuttings and mud threatened by the seismic activities.
impacts beginning on p. 81p please note that the total effects of
drilling fluids have generally been underassessed, and that effects
may occur at much greater distances than the immediate discharge site.

Specifically, the Marine Board study of 1983 cited on p. 82 is
not the 'state-of-the-art' document adequate to draw conclusions of
the impacts from full-scale development (as we hoped it would be).
The studies considered only the quantities from exploratory drilling
or from a few development wells, nml the tons of cuttings and fluids
from large, multi-welled operations we see on the West Coast.
7. EPA publislied an "Assessment of Environmental Fate and Effects of Discharges
The many specific components of the fluids used in various from Offshore Oil and Gas Operations (1985) that describes in detail the
studies reviewed were not reliably lenown. The report relied on short- different ccmpom@ of the drilling fluids, aittings and discharged water.
term (96 hour) laboratory studies of a limited number of species, and
emphasized in its summary the "incomplete under-standing of basic H-er, our understanding of the environmental transport fa4te and tmaclty
oceanic or biological processes" (as cited, p. 1). There were many of these compor-its is still nat fully umlerstood. Environmental factors that
cogent critiques of the panel's politics, data, methods of drawing affect the dispersion and transport of discharged material include waves,
conclusions, and the conclusions themselves. We call your attention airrent direction and velocity and bcttm tcpogaphy. The environmental
to the review "The National Research Council's Report on Drilling effects of the drilling materials and fluids are therefore very difficult to
Muds: Science Gone Awvy?" by Brandt Mannchen, Sierra Club, Texas. Pred-t- NQAA has Prchibited all discharges anci depositing of harmitul
subs@ances tliat -ter the Sanctuary and inj- Sar-tuary resmwces. NaAA Will
None of the drilling muds impact summaries loot, at the conti- to -tor U- Sancl:uary rescurces and the activities thilt could
variation in organisms or regions, the cumulative effects of many potentially injure those resources.
point sources in one area, or the low-level or long term effects.
They do not add the toxicity of the cuttings, or of the large
discharges of formation waters, which contain heavy metals and
carcinogens. The effects could easily be loss of several sensitive

benthic species in an exposed area, and impacts on up the food chain.

Even at highly dilute levels, drilling mud benthic deposits or
plumes may have critical effects on marine species. For example, very
low levels of drilling fluid suspensions were found by UC Santa
Barbara Marine Institute scientists to disrupt abalone larvae settling
behavior and other behavior of invertebrate organisms, as reported at
EPA Region IX hearings on the Draft NPDES Permit for' offshore
operation discharges, October 1985.
The biota of the Bank region below 35 fathoms, although not as 8. see Generic ResporLse E.
dense as that on the Bank itself, contributes to the food
availabili.ty, and would contribute to its loss or contamination if
affected. A prohibition of drilling to just beyond 50 fathoms would
not prevent that loss or contamination from reaching either the 'core
area' or the organisms further up the food chain that the Sanctuary
would protect.

Realistic distances for protection must be established based
on further research. What little is reported is suggestive that
distances presently assumed safe are too little. George Mariani in
the LaVe Buena Vista Symposium proceedings, p. 496, replied to a
question how far out during the Bal.timore Canyon drilling muds study
statistically significant elevations of levels of compounds were
found. "Two miles and that was the max,imum distance for which we
sampled. In that case it was observed for lead."

Jack H. Thompson, Jr., stated in the abstract of his doctoral
dissertation that concentrations calculated for plumes at more than 12
kilometers from the source would with some muds get behavioral
responses in some species of reef corals (Responses of Selected 9. See Above. Response No. 7.
Scleractinian Corals to Drilling Fluids Used in the Marine
Environment, Texas A&M, August 1980). With a rare hydrocoral and its
dependent species to protect on Cordell Bank, the prohibition of
drilling operations for a number of miles would be appropriate.

It is not sufficient to state (p. 82) "Department of Interior
OCS Ordeer Number 7 forbids the discharge of drilling muds containing
toxic substances into ocean waters,* and expect that we can assume
therefore that no toxics will be discharged. Please study the NPDES
hearing records for 1) the actual history of toxic discharges and
violations of regulations, and 2) the controversy over the adequacy of
the regulations, even assuming excellent compliancev to protect marine
organisms.

A ban on hydrocarbon activities in the adjacent Gulf of the
Farallons Marine Sanctuary was upheld by the findings of a 1982 study
whose conclusions also apply to the Cordell Bank. The oil that might
be forgone would be a very small fraction of that available for, our
needs.. The risks to the resources are significant, and the resources
are unique and some are endangered. We will likely be able to develop

that oil more safely in the future, and it will be there for us.

X**X**XN

One of us has been priviledged to see several of the
endangered Humpback Whales in the vicinity of the Bank, and it has
always been our dream to see a Great Blue Whale. We have seen slides
from a +light out to the Farallons which captured the passage of a
Great Blue Whale below the plane - a thrilling experience even second-
hand.

Reading the report of -forty-one Blue Whales observed in one
sighting from the Farallons (Gulf of the Farallons NMSP Sightings
Bulletin No. 2) is awe-inspiring and heartening. To have the
opportunity to see the largest animal on earth, one so scarce that the
entire world population is equal to that of one small town of humans,
is not something that can be easily measured with dollar values, but
has deep meaning for many people. (See attached poster for a
nonquantifiable indication of public interest in the Blue Whale.)

Consider the joy so rhainy people felt when they heard that
'Humphrey', the whale that wandered into San Francisco Bay not long
ago, had been re-identified in the Humpback population in the Gulf of
the Farallons. How can we value that joy except by seeing that the
opportunities to appreciate living whales are strongly protected off
our coasts?

Given the status of the animals' populations and
distributions, we should regard ourselves as very fortunate caretakers
indeed of a world heritage. We must do all we can to protect these
populations.

We are talking of protecting the habitat of unique, small reef
animals, and also of supplying a safe habitat for the greatest animals
in the world. If the sanctuary is to live up to its name, it needs to
provide the maximum protection consistent with its law.

Thant, you for your attention.

S, r ly,

u hann Corwin, PhD.
1 ce e

Robert R. Harriso

cc Mr. C. William Verity, Dept. of Commerce
Mr. Edward WilcynsPi, Dept. of Commerce
Congresswoman Barbara Boxer
3
0
Marin County Board of Supervisors

-W

NATIONAL ENVIRONMENTAL DAY, JUNE 4, 1977

CABRILLO BEACH, SAN PEDRO, CALIFORNIA

XF
r

BLUE WHALE 110 feet long, 14 feet wide

.took 649 people 6;@ hours to build.

CABRILCO MARINE MUSEUM
AMERICAN CETACEAN SOCIETY Department of Parks & Recreation
- 40- N Ci+v of Los Angeles

Sept.28,1987

Dear Acting Chief Allin,
I am commenting on the draft environmental impact
statement, draft management plan, and proposed rule for the
Cordell Bank National Marine 3anctuary. I strongly support
the preferred alternative(Alternative # 2; Boundary Alter-
native #2) to designate this sanctuary and protect its
fragile marine values. We request that the sanctuary
regulations be strengthened by prohibiting any off-shore oil
and gas exploration and development within the whole
sanctuary boundary. Thank you.

Yours truly,

L. D. Couey
5191 Sparrow Dr.
Huntington Beach, CA 92649

1. See Generic Response A.

2. See Generic Response B.

TERWILLIGER NATURE EDUCATION CENTER
50 El Camino Drive
Corte Madera, CA 94925-2057 (415) 9271670

Vickie Allin, Acting Chief
Marine Estuaries Management,
Office of Coastal Resource/NOAA
Washington, D.C. 20235

Dear Ms. Vicki Allin:

We the undersigned are in favor of expanding the peripheral boundaries
of the existing Cordell Ocean Sanctuary. We believe this rich biological
habitat must be saved from the threat of future oil drilling exploita-
tion.

1) William H. Randolph
PO Box 92
69 Sir Francis Drake Blvd
Ross, CA 94957

2) Christine Coughtern
PO Box 745
The Cottage at 35 Locust St.
Mill Valley, CA 94942

3) Sylvia Gray
58 Park Ter
Mill Valley, CA 94941

4) Calvin Terwilliger
308 Oakdale Ave
Mill Valley, CA 94941

5) Cynda Vegas
596 Woodbine Dr
San Rafael, CA 94903

1. See Generic Response A.

2. See Gemeroc Res[pmse B.

Paul F. Covel
2860 Delaware Street
Oakland, CA 94602

Sept 30 '87

Ms Vickie Allin
Acting Chief
Office of Ocean and Coastal
Research Management
National Ocean Service
1825 Connecticutt Ave NW
Washington, D.C. 20235

Comments on Cordell Bank

Dear Ms Allin:

In the case of the D.E.I., management plan and proposed rules for
the Cordell Bank National Marina Sanctuary - - I want to support
the preferred alternative -- Alternative #2 -- and Boundary Alter-
native #2 -- to designate this sanctuary. Also, please designate
that any and all off-shore oil and gas exploration and development
be prohibited within this sanctuary.\

Cordell Bank is a unique combination of oceanic topography, currents,
nutrient supplies and marine life, which far outweigh any possible
yields in mineral resources. It must be saved!

Respectfully yours,

Paul F. Covel

Copies to Mr. Edw. Wilczynski, US Dept of Commerce,
Senators Cranston and wilson, S.F. Bay Area congressmen.

1. See Generic Response A.

2. See Generic Response B.

Ms. Vickie Allin
1825 Connecticut Avenue, N.W.
Washington, DC 20235

Dear Ms. Allin,
I urge you to support the Cordell Bank Sanctuary off of Pt. Reyes
in California.

From what I understand, drilling for oil off the coast of
California would not appreciably improve this country's energy
needs. In fact, fossil fuel is on its way out! It is getting
more and more expensive to extract crude oil, and less and less
overall benefit is being derived from its use!
No Response Necessary.
The money spent in military operations involved in 'protecting',
our energy resources that we basically take from the Middle East,
could be used instead to support research and development of
native energy such as wind power, solar power, water (hydro) power,
and geo-thermal power.

Eventually this will happen anyway, as it is clear that fossil fuel
is on its way out. I have. heard of reports that estimate 1995 to
2005 as the time when crude oil will no longer be the source of
our basic energy needs.

In the meantime, there are unfortunately special interests who
want to get that last bit of drilling done. I think it is a shame
to allow them to do it at the expense of the integrity of the
Northern California coast and its wildlife.

Please support the Cordell Bank Marine Sanctuary!

Thank you!

Sincerely,

No Response Necessary.

October 7, 1987

Ms. Vicki Allin, Acting Chief
Marine and Estuarine Management Division
OCRM National Ocean Service/NOAA
1825 Connecticut Ave., NW
Washington, DC 20235

Dear Ms. Allin,

I am writing in support of establishing a Cordell Bank Marine Sanctuary
off the coast of Northern California. I don't know whose brilliant idea
this was, but it is the best conservation proposal in a long time.

I am sure your office is aware of the immense biological diversity that
now thrives in this sensitive area. I have known scuba divers and
fisherman alike to compare it to the Monteray Bay aquarium...only without
windows. Truly this area deserves a special measure of protection so that
we can continue to harvest the fishery resource that uses the Cordell Bank
for breeding, but also equally important to have an environment that can
be used for marine research purposes.

Marine mammals, seabirds, and fish utilize the area for their migrations.
The boundary alternative #1 is an obvious first choice for sanctuary
limits. But even the #2 boundary alternative would be more acceptable than
#3. The #3 alternative does not extend protection to the marine sphere
of influence that would be expected to impact the Cordell Banks. #1
alternative gives ample protection while #2 give marginal protection.

Between assaults by the Interior Dept. to open up tracts for offshore oil
and the potential for ocean discharges of sanitary waste, it is
increasingly important to establish areas that can continue in their
natural splendor to provide habitat for marine species. There should at
least be a ban on any oil exploration within the #1 boundary zone if
sanctuary status is not achieved.

The resource base within Cordell Bank is a special treasure that we should
make every effort to conserve so that future generations can continue to
enjoy the bounty of an undisturbed marine environment. By insuring that
the carrying capacity of the area is not impacted by oil development or
overfishing, the Cordell Bank can be a resource for many generations to
come.

Can you image not having national treasures like Yellowstone, Yosemite
and the Grand Canyon? It took a forward look and strong resolve to
make those places beyond the reach of economic exploitation. Please
consider establishing the Cordell Bank Marine Sanctuary with the most
extensive boundary possible.

Regards,

Linda Curry
747 Mill St.
Santa Rosa, CA 95404

"THE USS SOLACE WAS THERE'
Ensign H. C. 'Pat' Daly, MSC, USN Ret.
1951 28th Avenue (415) 731-4782
San Francisco, CA 94116

Ms. Vickie Allen, Acting Chief,
Marine and Estuarine Management Division,
Office of Ocean and Coastal Resource Management Div., 25 September 1987
National Ocean Service/ NOAA,
1815 Connecticut Avenue, N.W.,
Washington, D.C. 20235

Dear MS Allen:

I am writing to you as a concerned citizen, commenting on the draft environmental
impact statement, draft management plan, and proposed rule for the Cordell Bank
National Marine Sanctuary. I wish to express my strong support for the preferred
alternative #2, to designate this sanctuary and to protect its fragile marine
values. However, please request that this sancuary must be protected for its
fragile marine values by prohibiting off-shore oil and gas exploration and dev-
elopment within the entire sanctuary boundary.

If we can send a man to the moon, we should be able to protect the lives of our
treasured Marine Life and sanctuaries.

SINCERELY YOURS,

A concerned citizen,

Harold C. Daly

CC:

The Honorable C. William Verity Jr.,
Secretary of Commerce
Mr Edward Wilcznski, Acting Chief,
Ecology and Conservation Div, Dept., Commerce.
Senator Alan Cranston, (California)
Senator Pete Wilson, (California)
Richard Spotts, California Representive

1. See Generic Response A.

2. See Generic Response B.

September 29, 1987

Ms. Vickie Allin, Acting Cheif
Marine and Estuarine Management Division
Office of Ocean & Coastal Resource Management
National Ocean Service/NOAA
1825 Connecticut Ave., N.W.
Washington, D.C. 20235

Dear Ms. Allin

I am writing concerning the draft environmental impact
statement, etc. for the Cordell Bank National Marine Sanctuary.

Considering the rapid decline in the quality of the
I.arth's natural wonders and resources, I urge you to do all See Generic Response B.
you can to protect this sanctuary from oil exploration and any
other env ironmental degrading useage.

Sincerely,

Denise D'Anne
3.51 Guerrero St.
San Francisco, Ca. 94103

cc: Mr. Edward Wilczynski, Act ing Chief
Ecology and Conservation Division
Room 6814
U.S. Department of Commerce
Washington, D.C. 20230

Senator Alan Cranston

Senator Peter Wilson

1234,66

A
Iz.7
23

37 Calhoun Terrace
San Francisco, CA 94133

October 5, 1987

Ms. Vickie Allin
Acting Chief
Marine and Estuartine Mgmt. Div.
Office of Ocean and Coastal Resource Mgmt.
National Ocean Service/NOAA
1825 Connecticut Ave., N.W.
Washington, D.C. 20235

RE: DRAFT ENVIRONMENT IMPACT STATEMENT, DRAFT MANAGEMENT PLAN, PROPOSED RULE FOR CORDELL BANK

We wish to express our strong support for the preferred alternative (Alternative
#2 - Boundary Alternative #2) to designate this sanctuary and protect its
fragile marine values. The sanctuary regulations should be strenthened by
PROHITITING OFF SHORE GAS AND OIL EXPLORATION AND ANY OTHER DEVELOPMENT.

We cannot invision anything worse than exploiting this fragile eco-
system and all that is environmentally involved within its boundaries.

Thank you for considering this most important issue.

Sincerely,

Mr. and Mrs. Alberic de Laet

1. See Generic Response A.

2. See Generic Response B.

September 29, 1987

Ms. Vickie Allin, Acting Chief
Marine and Estuarine Management Division
Office of Ocean and Coastal Resource Management
National Ocean Service/NOAA
1825 Connecticut Avenue, NW
Washington, DC 20235

Dear Ms. Allin:

I am writing this letter to express my concern for the preservation of the Cordell I. See Generic Response A.
Bank National Marine Sanctuary. It is my understanding that drafts have been
implemented for an environmental impact statement and management plan, and for a
f1roposed ruling. I wish to express my strong su port for the preferred alternative
I (Alternative #2; Boundary Alternative #2) to lesignate this sanctuary and protect the
Lmarine life existing on and around the Bank boundaries.
2. See Generic Ret@:. B.
I would also like to request that sanctuary regulations be enforced and strengthened
by the prohibition of off-shore oil and gas exploration and development within the entire
sanctuary boundary.
11ank you for your consideration of my views.

Sincerely,

Michelle L Dethke
647 Beacon Street #4
Oakland, CA 94610

cc: Mr. Edward Wilczynski, Acting Chief, Ecology and
Conservation Division, US Department of Commerce
The Honorable C. W19liam Verity, Jr., Secretary of Commerce,
U.S. Department of Commerce
Senator Alan Cranston, U.S. Senate X34507&0
Senator Pete Wilson, U.S. Senate

OCT Ir

September 29, 1987

Ms. Vickie Allin, Acting Chief
Marine and Estuarine Management Division
Office of Ocean and Coastal Resource Management
National Ocean Service/NOAA
1825 Connecticut Avenue. NW
Washington, DC 20230

Re: Cordell Bank National Marine Sanctuary

Dear Ms. Allin:

I am writing in regard to the draft environmental impact statement.
draft management plan, and proposed rule for the Cordell Bank National
Marine Sanctuary.

In my opinion. the best plan is the Alternative #2 and Boundary Alternative
#2. Sanctuary regulations should be strengthened by prohibiting any off-
shore oil and gas exploration and development within the entire sanctuary
boundary.

Sincerely,

(Mrs.) Helene Dickard
356 Park Street
San Francisco, CA 94110

cc to Mr. Edward Wilczynski, the Honorable C. William Verity, Jr.,
Senator Alan Cranston, Senator Pete Wilson, the Honorable
Nancy Pelosi

1. See Generic Response A.

2. See Generic Response B.

Theresa A. Dillon
69 Point San Pedro Road
San Rafael, CA 94901
October 8, 1987

Vickie Allin, Acting Chief
Marine & Estuarine Management Division
Office of Ocean & Coastal Resources Mgmt.
National Ocean Service/NOAA
Washington D.C. 20235

Re: Cordell Bank

Dear Ms. Allin:

I understand that Cordell Bank off of Point Reyes is
under consideration for designation as a marine sanctuary,
and that the public is invited to comment on such.

Although my knowledge on this subject is limited, I do
know enough to realize that the establishment of a marine
sanctuary in the area contemplated is necessary and would be
beneficial.

Cordell Bank is a sea mount supporting an elaborate
biological community. It is invaluable for environmental
studies in biogenetics and phylogenetics of an isolated
biotic community. Several previously unclassified species
have been discovered at Cordell Bank amongst the rich animal
life that abounds there. In addition, it is home to the
federally protected California hydrocoral.

Ocean water covers almost 71% of the Earth's surface.
only a small portion of the ocean--the shallow coastal
waters--is biologically productive. over 60% of the world's
total marine catch comes from the continental shelves. Yet
this productive shallow water is the site of heavy oil tanker
traffic and off-shore drilling rigs, and consequently where
the major oil spills occur (as well as industrial pollution
and toxic waste dumping). Our entire coastline is already in
jeopardy from oil contamination, and the advent of increased
off-shore drilling will only place it in greater jeopardy.
The Puerto Rican and, more recently, the Pac Baroness can
attest to this very real hazard.

October 8, 1987
Page -2-

It is therefore vital to protect these areas from such
dangers, especially geologically unique areas like Cordell
Bank. I would strongly urge you to approve designation of
Cordell Bank as a marine sanctuary, and allow for a wide
buffer zone to ensure that it will not be encroached upon.
The integrity of our coastal habitat, and our future, depend
upon it.

Very truly yours,

THERESA A. DILLON

/tad

1. See Generic Response A.

Susan Dinsmore
1132 Cole Street
San Francisco, California 94117

October 8, 1997

Ms. Vickie Allin, Acting Chief
Marine and Estuarine Management Division
Office of Ocean and Coastal Resource Management
National Ocean Service/NOAA
1825 Connecticut Avenue, N.W.
Washington, D.C. 20235

Dear Ms. Allin:

I am writing to express support for Boundary Alternative NO. 1 for Cordell Bank.

I wish there to be a complete ban on all hydrocarbon and other mining and
mineral activity at Cordell Bank. There should be a ban on these activities
from the outset.

I have dived Cordell Bank on numerous occasions and use the coastal areas in
the area. I have been delighted by the wonderful life on the Bank. Having
dived in almost every part of the world from Tahiti to Vancouver to Africa I
am convinced that the Cordell Bank is a unique and therefore a priceless and
valuable resource for our country. To defile this area with drilling or mining
or developmental activity of any kind would be a crime.

Other people I am familiar with in Marin and in the ecological circles in the
Bay Area know of the forthcoming designation of Cordell Bank as a Marine
sanctuary. There is a good deal of ridicule from these people for the idea of
Cordell Bank allowing developmental activity. They believe as I do that if you
are going to designate a Marine Sanctuary, then it ought to be just that, not
a sell-out to commercial interests. I would be interested in what justification
there exists to allow any activity in that area. I could not see that any
such activity would be justified, and neither do any of the people I know.

Therefore I support Boundary Alternative NO. 1, and wish there to be no allowance
for any development from the outset.

Sincerely,

Susan Dinsmore

1. See Generic Response A.

2. See Generic REsponse B.

711 Alameda
Redwood City, Calif.94061
Sept. 28, 1987
Dear Acting Chief Allin,
I am commenting on the draft environmental impact
statement, draft management plan,and proposed rule for the
Cordell Bank National Marine Sanctuary. I strongly support
the preferred alternative (Alternative # 2; Boundary Alter-
native # 3) to designate this sanctuary and protect its
fragile marine values. We request that the sanctuary
regulations be strengthened by prohibiting any off-shore oil
and gas exploration and development within the whole
sanctuary boundary.Thank you.
Yours truly,

Mr. & Mrs. L. DuPertuis

1. See Generic Response A.

2. See Generic Response B.

9 October 1987

Ms. Vickie Allin, Acting Chief

Marine and Estuarine Management Division
Office of ocean and Coastal Resource Management
National ocean Service/NOAA

1825 Connecticut Avenue, N. W.

Washington, D. C. 20235

Dear Ms. Allen:

I would like to take this opportunity to express my support for
designating Cordell Bank as a National Marine sanctuary.
I have been an active member of the Cordell Bank Expedition for
ten years and as'a diver and underwater photographer I have had
the opportunity to observe and photograph the flora and fana first

hand.

on my first dive, it was instantaneously apparent that Cordell

Bank was like no other place I have dived anywhere along the

California Coast. Among some of the most notable features on Cordell

Bank were:

1) Clearness of the water (visibility) resulting in high light level.

2) An extremely healthy and abundant growth of marine biota.

3) Large numbers of schooling fish.

Clearly Cordell Bank exhibits an area of high productivity,

ranging from the bottom dwelling organisms to the bird

and mammal population it supports. Part of this high

productivity is due to its unique location on the edge of

the continental shelf. Here the upwelling of nutrient rich
water from the ocean bottom combined with high light level

makes Cordell Bank a most unique place, a place unsurpassed
anywhere along the California Coast.
In addition, many undescribed species and one genus have been

found on Cordell Bank and I believe there is a high probability

of discovering more new organisms living on Cordell Bank.

Cordell Bank still remains in a pristine state, virtually

undisturbed by human intervention. we now have an opportunity to

ensure it remains this way by declaring it as a national marine
@
sanctuary. Furthermore, to provide maximum protection to Cordell
Bank lam in favor of adopting boundary alternative #1 and above 1. See Generic Response A.
all allowing no hydrocarbon activity within this boundary. 2. See Generic Response B.

Thank you for taking the time to read this letter and I hope

you found my comments useful.

Sincerely,
i) --j-t ;@) k) "@
Donald D. Dvorak

2218 Ventura Place

Santa Clara, CA. 95051

too

216 Carmel Avenue
El Cerrito, CA 94530
9 October 1987

Ms. Vickie Allin, Acting Chief
Marine and Estuarine Management Division
Office of Ocean and Coastal Resource Management
National Ocean Servoce/NOAA
1825 Connecticut Avemie, N. W.
Washington, D.C. 20235

Dear Ms. Allin,

I am writing to support the creation of the Cordell Bank National
Marine Sanctuary. I favor Boundary RAlternative # 1, which I. See Generic Response A.
Includes the largest area of those proposed. I consider it
imperative that all activities relating to hydrocarbon
development or exploration (offshore test drilling, all rigs, etc.)
be prohibited in this area from the start. I also recommend that
there be some provision made for monitoring the area. I further
suggest that there be a ban on activities that involve actual
contact with the ridges, as by anchoring there, since the
organisms growing there are exposed to and will be damaged bg
anything that touches the bottom.

I know that this is an exceptionally rich area for subtidal rocky
substrate dwellers, as I am one of the few people who has dived
there. I am a scientist by training and profession, I am an
underwater photographer, and I have studied marine biology for
several years.

Sincerely yours,

Sue J. Estey, Phd

1. See Generic Response A.

2. See Generic Response B.

3. See Generic Response D.

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1. see Generic Response A.
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2. See Generic Response B.

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Mike Farmer
IOU Sierra Drive
Petaluma, CA
Oct. 10, 1987

MS. Allin,

I am writing this letter to you in regards to the designation of Cordell
anks, CA, as a National Marine Sanctusry. I feel that it is imperative 1. See Generic Response A.
that the area boundary #1 be established for the protection of this very
unique and pristine area. I wish to express my adamant desire the the 2. See Generic Response B.
entire area have a ban on all hydrocarbon activity. I cannot emphasize
enough the importance of the ban. One only needs to see some of the
p otographs and video of the underwater area to see how fragile this area
is, and see how detrimental to the area that would be possible should
hydrocarbon activity be allowed. I must insist that as a concerned American
citizen, this area receive the entire support you can give it in this
direction. I will do everything in my power to see that this area be
protected. A great number of my friends and relatives feel the same way.
We completely support the Area Designation Boundary No. 1, and a ban
on all hydrocarbon activity, and further request that additional funds 3. See Generic Response G.
for on site monitoring, and that provisions for enforcing the regulations
e ammended to include a ban on all contact with the shallow ridges (such 4. See Generic Response D.
as anchoring). We wil I do al1 that we can to fight for these recommendations
and additional funding as necessary to preserve this beautiful area.
Thank you.

Sincer.ly

0
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October 07, 1987

Ms. Vickie Allin
1825 Connecticut Ave.
Washington D.C. 20235

Dear Ms. Allin,

I further support both the formation of BOUNDARY #1 in hopes of provid-
ing the broadest area of protection, and a ban on all offshore oil
drilling activity including leasing, exploration and developement
within the Cordell Bank Marine Sanctuary.

Sincerely,

Bea Flint

Box 298
Point Reyes, CA 94956

1. See Generic Response A.

2. See Generic Response B.

October 07, 1987

Ms. Vickie Allin
1825 Connecticut Ave.
Washington D.C. 20235

Dear Ms. Allin,

I would like to express and extend my support for the proposed creation
of the CORDELL BANK MARINE SANCTUARY. I am aware, as are many people,
of the devastating effects offshore oil drilling would have on the
marine life and enviornment.
[
Ifurther support both the formation of BOUNDARY #1 in hopes of proid- 1. See Generic Response A.
ing the broadest area of protection. and a ban on all offshore oil
rilling activity including leasing, exploration -@nd developement 2. See Germ-Xic Response B.
wi thin the Cordell Bank Marine Sanctuary.

Sincerely
Q'--@"L I

AJ 0 -1

3 -7
9101172,

September 30, 1987

Ms. Vickie Allin, Acting Chief
Marine and Estuarine Management
National Ocean River Service/NOAA
1825 Connecticut Ave., N.W.
Washington, D.C. 20235

Re: Draft EIR and Management Plan and Proposed Rule for
the Cordell Bank National Marine Sanctuary

Dear Ms. Allin:
Al am writing to register my STRONG SUPPORT FOR
LTERNATIVE #2; BOUNDARY ALTERNATIVE #2 to designate this 1. See Generic Pasponse A.
sanctuary and protect its fragile marine life,

Please also strengthen the sanctuary regulations by PROHIBITING
ANY OFF-SHORE OIL AND GAS EXPLORATION AND DEVELOPMENT 2. See Generic Response B.
WITHIN THE SANCTUARY BOUNDARY.

Cordell Bank, located 20 miles west of Point Reyes, supports an
incredibly diverse and abundant array of marine creatures. Let us
preserve and protect this natural wonder for future generations.

Sincerely,

q i -5q

cc: Mr. Edward Wilczynski, Acting Chief
Ecology and Conservation Division, RM 6814
U.S. Dept. of Commerce
Washington, D.C. 20230

The Honorable C. William Verity, Jr.
Secretary of Commerce
U.S. Dept. of Commerce
Washington, D.C. 20230

Senator Pete Wilson and Senator Alan Cranston
Senate Office Building
Washington, D.C. 20510

1. See Generic Resporlse B.

2. See Generic Response c.
ell 1117

Edith N. FRIED
21 CROWN TERRACE
SAN FRANCISCO. CALIFORNIA 94114

September 30, 1987

Ms Vickie Allin
Acting Chief, Marine & Estuarine Management Division
Office of Ocean & Coastal Resource Management
National Ocean Service/NOAA
1925 Connecticut Avenue, N.W.
Washington, D.C. 20235

Dear Ms Allin,

Re: Draft Environmental Impact Statement
for Cordell Bank National Marine Sanctuary.
I wish to express my support for the preferred
Alternative #2 to designate this sanctuary and pro-
tect its marine life. However, this alone is not
enough. I would urge you to strengthen the regulations 2. See Generic Response B.
and prohibit any off-shore gas and oil exploration
within the boundaries of the sanctuary. We Cali-
ornian environmentalists live in fear that our
coast will be ravaged and our marine wild life
destroyed. How can we explain to future generations
that we just sat inactive while greed and exploita-
tions took over our coast and devasted it?

Sincerely

Edith Fried

CC: Edward Wilczynski, US Dept of Commerce
Hon C. Wm Verity, Jr, SecretarY of Commerce
Senator Alan Cranson
Senator Pete Wilson

1. See Generic Response A.

2. See Generic Response B.

1.2-3S
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Als. A /11@, hr-@ij C41?,4,
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1. See Generic Response A.

2. See Generic Response B.

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CC: Air. EduArd Cuilc
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Tina Frisco
647 Beacon St., #3
Oakland, CA 94610
29 September 87

Vickie Allin, Acting Chief
Marine and Estuarine
Management Division
Office of Ocean and
Coastal Resource Management
National Ocean Service/NOAA
1825 Connecticut Avenue, N.W.
Washingtong D.C. 20235

Dear Ms. Allin:

I am writing to comment on the draft environmental impact
statement, draft management plan, and proposed rule for the
Cordell Bank National Marine Sanctuary.
I strongly support the preferred alternative (Alternative
#2; Boundary A;termatove #2) to designate this sanctuary and
protect its fragile marine values.
I request that the sanctuary regulations be strengthen by
prohibiting any off-shore oil and gas exploration and development
within the whole sanctuary boundary.

I would appreciate hearing from you on this matter. Thank
you.

Sincerely,

Tina Frisco

cc: Edward Wilczynski -- Dept. of Commerce
C. William Verity Jr. -- Sec. of Commerce
Senator Alan Cranston
Senator Pete Wilson
Rep. Ronald Dellums

1. See Generic Response A.

2. See Generic Response B.

Ms. Vidde Affin, Acting Chief
Marine and Estuarine Management Diovision
Office of Ocean and Coastal Resource Management
National Ocean ServiceINOAA
1825 Connecticut Avenue, NW
Washington, D.C. 20235

Dear Ms AUin:
I am writing to express my support for Boundary Alternative #1 for the proposed Cordell Bank
National Marin Sanctuary, for support of a complete and total ban on all hydrocarbon activity withing 1. See Ceneric Resporse A.
e sanctuary boundary. and to urge you to put these provisions into the sancuiary designation document
at the outset. Additional funds should be designated for supporting on-site monitoring. and the provi- 2. See Generic Resporise B.
IAEL ons; for enforcing the regulations should be arnmended to include a ban on aH contact with the sea
floor in this sanctuary-such as anchoring, etc. 3. See Generic Response G.
The preservation of such a sanctuary is mandatory if we are to have any natural history heritage
to hand down to the next generation. No significant sedimentary basin exists in the vicinity of the pro- 4. See Generic Response D.
posed sanctuary so eliminating it from hydrocarbon exploration activities can not cause anything but the
obligatory hew and cry from the petroleum companies. 'They can not be seriously considering this area
for anything but a precedent. What possible reasons could they have that would jeprodize the fragile
biota and the tmique environment of Cordell Bank?
I urge you to seriously consider the implications of not defining the Cordell Bank National
Marine Sanctuary as a true maring sanctuary.

Sincerely,
_Z__LV( 6&'
James V. Gardner
1850 Sunshine VaHey Road
Moss Beach, CA 94038

@*,,, -,253 14

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fl

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1. See Generic Response B.

2. See Generic Response A.
I Jk

ink

@X_,v I @vc US 6 @1'

1. See Goleric Response A.

00- 2. See Generic Response B.
V7,

October 07, 1987

Ms. Vickie Allin
1825 Connecticut Ave.
Washington D.C. 20235

Dear Ms. Allin,

I would like to express and extend my support for the proposed creation
of the CORDELL BANK MARINE SANCTUARY. I am aware, as are many people,
of the devastating effects offshore oil drilling would have on the
marine life and enviornment. I- See Generic Pespcnse A.
Ifurther support both the formation of BOUNDARY #1 in hopes of proid- 2. See Generic ResporLqe B.
[ing the broadest area of protection, and a ban on all offshore oil
drilling'ictivity including leasing, explration'@n-d developement
wi thin the Cordell Bank Marine Sanctuary.

Sincerely,

Frederick Gray
No V-a

/'@ 0S

Al,

D, C,

-t-4

2AC

1. See Generir- Response G.

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1- See Genexic Response A.
6@y
2. See Generic Response B.
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5 October 1987

1152 Jackson # 5
San Francisco, Ca
C. William Verity Jr. 94133
Secretary Designe
U.S. Dent of Commerce

Dear Mister Verity

Your assistance is needed to protect an endangered area off of
California's north-rn coast.

The opportunity to crest a unique marine sanctuary comes but once
and to this end I urge you to take all posible steps to protect the Cordell
nk in its entirety. The DEIS for this area lists three possible configurations. 1. See Generic Respcnse A.
Only alternative # 1 is acceptable due to pelagic consideration. To make
a marine sactuary without a buffer zone would be foolhardy in the extreme:
ld any provisions that might allow future exploitation for petroleum 2. See Generic Response B.
minerals. One:does not creat with the right hand only to destroy with

the left.
Please use your position and your conscience to protect an unreplaceable

treasure,

Sincerely

David Hoffman

4es

V,@,-

Aue- Al co

b,,y
61r-
@,,e 77, 1 X""
7@v'e_

,o es 1. See Generic Response A.
Yr
all C)4NOnf- alr",11, 2. See Generic Response B.

11717

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October 07, 1987

Ms. Vickie Allin
1825 Connecticut Ave.
Washington D.C. 20235

Dear Ms. Allin,

I would like to express and extend my support for the proposed creation
of the CORDELL BANK MARINE SANCTUARY. I am aware, as are many people,
of the devastating effects offshore oil drilling would have on the
marine life and enviornment.
I further support both the formation of BOUNDARY #1 in hopes of proid- 1. See Generic Response A.
ing the broadest area of protection, and a ban on all offshore oil
drilling activity including leasing, exploration and developement 2. See Generic Response B.

within the Cordell Bank Marine Sanctuary.

Sincerely,

Deborah J. Jackson
San Rafael, CA

Peggy Johnson
3 Branch Road
Larkspur, CA
Oct.10, 1987

MS. Allin,
I am writing this letter to you in regards to the designation of Cordell 1. See Generic Response A.
anks, CA, as a National Marine Sanctusry. I feel that it is imperative
that the area boundary #1 be established for the protection of this very 2. See Generic Response B.
unique and pristine area. I wish to express my adamant desire the the
entire area have a ban on all hydrocarbon activity. I cannot emphasize
Rough the importance of the ban. One only needs to see some of the
photographs and video of the underwater area to see how fragile this area
is, and see how detrimental to the area that would be possible should
hydrocarbon activity be allowed. I must insist that as a concerned American
citizen, this area receive the entire support you can give it in this
direction. I will do everything in my power to see that this area be
protected. A great number of my friends and relatives feel the same way.
We completely support the Area Designation Boundary No. 1, and a ban
on all hydrocarbon activity, and further request that additional funds
for on site monitoring, and that provisions for enforcing the regulations 3. See Generic Response G.
e ammended to include a ban on all contact with the shallow ridges (such
as anchoring). We will.do all that we can to fight for these recommendations 4. See Generic Response D.
and additional funding as necessary to preserve this beautiful area.
Thank you.

Sincerely,

Iffis 16
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IRIS KAKUGAWA
Regional Trainer
#am Longs Son Nw 0.0.
55W center Dr 7'V
Lo Meak CA 92041

Mr. c. William verity, Jr., Secretary Designs .3, T
United states Department of Commerce
Washington, D. C. 20230 LS
N>
October 8, 1987

Dear Mr. C. William Verity, Jr.,

-
uld like to express My BUPPort for Boundary Alternative #1. 1. See Generic Response A.
d-sira a complete and total ban an ALL hydrocarbon activity
w
@i4 in the sanctuary boundary, and insist that these provisions
be included in the sanctuary designation document AT THE OUTSET. 2. See Generic Response B.
I recommend that additional funds be designated for supporting 3. see Generic Response G.
-site monitoring, that provisions for enforcing the regulations
E amended to include a ban on all contact with the shallow 4. See Generic Response D.
br.-idges (such as anchoring).

I have seen this beautiful place in photos and videos, and
believe it to be an extraordinarily rich benthic community of
life; the home of very rare and unusual species of hydrocorals,
sponges, scallops, and snails with an abundance of fish, and
other (some endangered) marin; life.
I strongly support Sanctuary status for the Cordell Bank area,
and recommend that the OCS ban be extended to include the whole
Sanctuary, not just the core area.

Please help us prevent the offshore oil and gas exploration and
development that would change, destroy, and mutilate any of the
Cordell Bank Marine Sanctuary.

Sincerely,

Ms. Vickie Allin, Acting Chief September 29, 1987
Marine and Estuarine Management Division
Office of Ocean and Coastal Resource Management
National Ocean Service/NOAA
1825 Connecticut Avenue, N.W.
Washington, DC 20230

Re: Designation of the Cordell Bank National Marine Sanctuary

Dear Ms. Allin:

I am commenting on the draft environmental impact statement, draft
management plan, and proposed rule for the Cordell Bank National
Marine Sanctuary. I wish to express my strong support for the 1. See Generic Response A.
preferred alternative (Alternative #2; Boundary Atlernative #2) and to
request that sanctuary regulations be strengthened by the prohibition 2. See Generic Response B.

of any off-shore oil and gas exploration and development within the
sanctuary boundary.

Sincerely,

(Miss) Verna E. Larson
175 Middlefield Drive
San Francisco, CA 94132

cc to: Edward Wilczynard, J. William Verity, Senator Alan Cranston, Senator Pete
Wilson, and Representative Nancy Pelosi.

October 9, 1987

Dear Ms. Allin,

RE: PROPOSED CORDELL BANK MARINE SANCTUARY

I was pleased to hear the results of the recent public hearings in
the San Francisco Bay area - public testimony overwhelmingly in
s
pport of designation, and unanimous in recommendi g an enlarged
u i ty i
boundary w th no hyd oca in th
iv! . O;nywher. with
I would 1@ rboZaZ:tth portunity to add my support
sanctuary. k. to
tF
tor jese provisions and to further recommend additional
provisions.

My formal training and in situ studies in Marine Biological
Science and the observa-tio-nsI have made personally in a number of
dives on Cordell Bank have helped me realize the extraordinary
uniqueness of this place as an abundant, diverse and relatively
unaffected self-sustaining ecosystem. Sadly, a submarine system
w_1Fh_ Ehese special attribUt-e--s-10 -one that can be studied readily
and offer a benchmark for future generations is rare in the world
today. Realizing these things I believe it is our duty to provide
am rt n: gement provisions that will assure protection into the
fu:urem:n comply with public desire.

I strongly support the Boundary Alternative #1 (to include waters 1. See Generic Response A.
surrounding Cordell Ban-kT-and a complete and total ban on ALL
hidrocarbon v1ty ithin the sanctuary boundary and that these 2. See Generic Response B.
i i
rovisions d41ncludewd n the sanctuary designation document at
the outset and be maintained clearly and consistently through3-ut
a I versio of the docume
i :ions nt. Also, I strongly recommend that
3 add tio a 1 funds be designated for on-site monitoring to verify 3. See Generic Response G.
Iu pliance, and that provisions for enforcing the regulations be
6h
r
Pa d
c
ammended to include a ban on all contact with the shallow ridges 4. See Generic Response D.
ismuch as anchoring). As you know the shallow ridges are inhabited

Ms. Vickie Allin
Page 2
October 9, 1987

by the most delicate of organisms in the designated area and are
those 'indicator' organisms that should be closely protected. I
have personally seen damage of rare hydrocoral beds and sponge
aggregations in these exposed areas caused by man's activities.

I want to be sure that my support and my additional
recommendations for the Cordell Bank Sanctuary Designation will be
addressed and placed in the record. Please respond.

And thank you for your fine work in establishing standards and
protecting resources important to health, understanding and smart
management in tomorrows world.

Very t uly your

te en wler
226 itor Court
San Jose, CA 95125
408 723-2008
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ANNE LA~LYZE~I~I ~9 Z4 ~I~MEAT~qE~qM WAY ~9 MILL VALLEY CA 9~4~q%1 (41~q5) 3~qU-~S~0qW

October 2, 19~q87

Dear Vickie Alli~n~,

I support the creation of the Cordell Bank Marine Sanctuary. The area is
a particularly precious treasury of wildlife, including several endangered 1. see Generic Response A.
~ ~8 ~' s. I support the Boundary Alternative ~# I and the inclusion of a ban on 2. see Generic Response B.
offshore drilling activities, including leasing, exploration, and develop-
me~nt, within the entire Sanctuary from the very be

Yours Sincerely,
~2qA~'~L~-~4q@ a ~-

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Of- s 1. See Generic RespOnse B.
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927 T.M--l Sb"
[email protected],494116
10

1345 Taylor Street #26
San Francisco, CA 94108
October 7, 1987

Ms. Vickie Allin
Acting Chief
Marine and Estuarine Management Division
OCRM
National Ocean Service/NOAA
1825 Connecticut Avenue, NW
Washington, DC 20235

Dear Me. Allin:
I am writing to express my strong support for the 1. See Generic Response A.
designation of the Cordell Bank, west of Pt. Reyes,
as a marine sanctuary. I also support boundary
alternative #1, for protection of the broadest area. 2. See Generic Response B.
I oppose all drIlling activities in this area, from
leasing on, and ask for your help in establishing a
fIrm ban.

Thank you.

Sincerely,

Michele Liapes

October 07, 1987

Ms. Vickie Allin
1825 Connecticut Ave.
Washington D.C. 20235

Dear Ms. Allin,

I further support both the formation of BOUNDARY #01 In hopes of proid- 1. See Generic Response A.
ing the broadest area of protection, and a ban on all offshore oil
drilling activty including leasing, exploration and developement 2. See Generic Response B.
wIthin the Cordell Bank Marine Sanctuary.

Sincerely,

Gloria Lightner

San Rafael, CA

September 30, 1987

Ms. Vickie Allin, Acting Chief
Marine and Estuarine Management
National Ocean River Service/NOAA
1825 Connecticut Ave., N.W.
Washington, D.C. 20235

Re: Draft EIR and Management Plan and Proposed Rule for
the Cordell Bank National Marine Sanctuary
Dear Ms. Allin: 1. See Generic Response A.
I am writing to register my STRONG SUPPORT FOR
ALTERNATIVE #2; BOUNDARY ALTERNATIVE #2 to designate this
sanctuary and protect its fragile marine life.

Please also strengthen the sanctuary regulations by PROHIBITING
ANY OFF-SHORE OIL AND GAS EXPLORATION AND DEVELOPMENT 2. See Generic Response B.
WITHIN THE SANCTUARY BOUNDARY.

Cordell Bank, located 20 miles west of Point Reyes, supports an
incredibly diverse and abundant array of marine creatures. Let us
preserve and protect this natural wonder for future generations.

Sincerely,

151
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HELLER, EHRMAN, WHITE & McAULIFFE
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......... . .......

333 ~8USH STREET-SAN FRANCISCO, CALIFORNIA 94104~-2878
~.~.~. CABLE H~ELP~O~W ~- TELEX 1~04 ~995 ~- TEL~E~CO~PI~ER -~S) 7-~.2~6~8 .~0 . ...
TELEPHONE (415) 772~-6000 ~1-~1 .... .. ... ~1.
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WE~X~M~A~N ~1. LUNDQUIST 7~q0~q932~q7~-
A October 1, 1987 ~q-

~T~

The Honorable C. William Verity, Jr.
Secretary of Commerce
U.S. Department of Commerce
Washington, D.C. 20230

Dear Judge Verity:

I am a supporter of Defenders of Wildlife and hereby
comment on the draft environmental impact statement, draft
m ~'anagement plan, and proposed rule for the Cordell Bank National 1. See Generic Response A.
arine Sanctuary. I strongly support the preferred alternative
Alternative #2; Boundary Alternative #2) to designate this
~2qQ~lanctuary and protect its fragile marine values. By prohibiting
C~0qj [~6qof~f~l~-eshore oil and gas exploration and development within the
wh sanctuary boundary, we can strengthen the Cordell Bank 2. See Generic Response B.
a
a
~ctuary.

I
~@~Very t ruly yours,

~@~7~q/

936 Wisconsin Street
San Francisco, CA 94107
October 8, 1987

',Is. Vickie Allin
Acting Chief, MArine and Estuarine Management Division
Office of Ocean and Coastal Resource Management
National Ocean Service/YOAA
1B25 Connecticut Avenue NY.'
Washington DO 20235

Dear Ms. Allin,

Cordell Bank

The purpose of this letter is to comment on the draft
environmental impact statement, draft management plan and proposed rule
for the Cordel Lank National MArine Sanctuary.

I wish to express my strongest support for Alternative 2,
Boundary 2; but urge that the regulations be strengthened to prohibit See Generic Response A.
absolutely all forms of off-shore oil and gas exploration and development
inside the sanctuary boundary. The greed and rapacity of the oil and gas 2- see Generic ReSPOnse B.
ekers must be curbed while there are sanctuaries left.

Sincerely,

Anne Mackarness

Copies to: iron. C. William Verity, Jnr., Secretary of Commerce
Fr. E. Wilczynski
Senator Alan Cranston
Senator Pete Wilson
R
I
Barbara Boxer

-46

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A- tj A-t,
F, 1. See Generic ReSPOnse B.

z
&,brc-A i@ CA cl Lici2)

hl,eo-A.
IJ-

AL@egNATWE I fa-,- 1. See Generic Response A.

k,.- 5-1-@ J! 2. See Generic Response B.
1INb C C o,7_4n
SANCIL)AII@ fv,)tv@Af'j'

Jack Marshall
2046 Leese Lane
Novato, CA 94945

Ms. Allin,

I am writing this letter to you in regards to the designation of Cordell
rBanks, CA, as acNational Marine Sanctusry. I feel that it is imperative 1. See Generic Response A.
L.that the area b undary #1 be established for the protection of this very
unique and pristine area. I wish to express my adamant desire the the 2. See Generic Response B.
ntire area have a ban on all hydrocarbon activity. I cannot emphasize
Cenough the importance of the ban. One only needs to see some of the
photographs and video of the underwater area to see how fragile this area
is, and see how detrimental to the area that would be possible should
hydrocarbon activity be allowed. I must insist that as a concerned American
citizen, this area receive the entire support you can give it in this
direction. I will do everything in my power to See that this area be
E
ro tec ted*A great number of my friends and relatives feel the same way.
e completely support the Area Designation Boundary No. 1, and a ban
on all hydrocarbon activity, and further request that additional funds 3. See Generic Response G.
for on site monitoring, and that provisions for enforcing the regulations
be ammended to include a ban on all contact with the shallow ridges (such 4. See Generic Response D.
as anchoring). We will do all that we can to fight for these recommendations
and additional funding as necessary to preserve this beautiful area.
Thank you.

Sincerely,

,,12 141

CICT 1987

October 9, 1987

Ms. Vickie Allin
Acting Chief, Maine and Estuarine Mqmt. Div.
Office of ocean and Coastal Resource Management
National Ocean Service/NOAA
1825 Connecticut Avenue, N.w.
Washington, D.C. 20235

Dear Ms. Allin:
Subject. Draft environmental impact statement
Draft management plan
Proposed rule for the Cordell Bank
National Marine Sanctuary

I strongly support the Preferred alternative (Alternative 1. See Generic Response A.
#2) to designate this sanctuary
and protect its fragile marine values. 2. See Generic Response B.
reguest that the sanctuary regulations be strengthened
by prohibiting any off-shore oil and gas exploration and
'development within the hole sanctuary boundary.
Sincerely,

Elizabeth J. Mathews
Mrs. Charles D. Mathews)

342 Hill Street
San Francisco, CA 94114

Ms. Allin,

I am writing this letter to you in regards to the designation of Cordell
nks, CA, as a National Marine Sanctuary. I feel that it is imperative
that the area boundary #1 be established for the protection of this very 1. See Generic Response A.
nique and pristine area. I wish to express my adamant desire the the
entire area have a ban on all hydrocarbon activity. I cannot emphasize 2. See Generic Response B.
enough the importance of the ban. One only needs to see some of the
photographs and video of the underwater area to see how fragile this area
is, and see how detrimental to the area that would be possible should
hydrocarbon activity be allowed. I must insist that as a concerned American
citizen, this area receive the entire support you can give it in this
direction. I will do everything in my power to see that this area be
@
rotected. A great number of my friends and relatives feel the same way.
e completely support the Area Designation Boundary No. 4, and a ban 3. See
n all hydrocarbon activity, and further request that additional funds Generic Response G.
r on site monitoring, and that provisions for enforcing the regulations
e ammended to include a ban on all contact with the shallow ridges (such 4. See Generic Response D.
s
a anchoring). We will do all that we can to fight for these recommendations
and additional funding as necessary to preserve this beautiful area.
Thank you.

Sincerely,

Al
th
n
en
Pen

IRV

September 30, 1987

Ms. Vickie Allin, Acting Chief
Marine and Estuarine Management
National Ocean River Service/NOAA
1825 Connecticut Ave., N.W.
Washington, D.C. 20235

Re: Draft EIR and Management Plan and Proposed Rule for
the Cordell Bank National Marine Sanctuary

Dear Ms. Allin:
(
I am writing to register my STRONG SUPPORT FOR
ALT ERNATIVE #2; BOUNDARY ALTERNATIVE #2 to designate this 1. See Gexieric Response A.
sanctuary and protect its fragile marine life.
[AIPIease also strengthen the sanctuary regulations by PROHIBITING
Y FF-SHORE OIL AND GAS EXPLORATION AND DEVELOPMENT 2. See Generic Response B.
WITHIN THE SANCTUARY BOUNDARY.

Cordell Bank, located 20 miles west of Point Reyes, supports an
incredibly diverse and abundant array of marine creatures. Let us
preserve and protect this natural wonder for future generations.

Sincerely,
@@@ m
1,16Z
F
cc: Mr. Edward Wilczynski, ActingXhief
Ecology and Conservation Division, RM 6814
U.S. Dept. of Commerce
Washington, D.C. 20230

The Honorable C. William Verity, Jr.
Secretary of Commerce
U.S. Dept. of Commerce
Washington, D.C. 20230 ---- 6
23

Senator Pete Wilson and Senator Alan Cranston
Senate Office Building
Washington, D.C. 20510 OCT

cl f(L @A c Kc/it.
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Tkk
14

1. See Gmeric Resp-
-"2-) TO:

N F-L

2. Se. G.,.ric p..@ B.
J,#4
b e-

NIA CJ-f@

Karen A. Mendelow
1661 Grove Street
San Francisco, CA 94117

September 14, 1987

Ms. Vickie Allin
Acting Chief
Marine & Estuarine Management Division
Office of Ocean & Coastal Resource Management
National Ocean Service/NOAA
Washington, D.C. 20235

Dear Ms. Allin-

I am writing to you in support of the establishment of the California Ocean National
Marine Sanctuary at Cordell Bank Sea Mount.

As a naturalist and whale watch expeditions leader for the Whale Center in Oakland,
California I have been out on many nature expeditions to view the abundant marine
wildlife along the California coast. In fact, last weekend I was out on a trip to the
Pt. Reyes-Farallon Islands National Marine Sanctuary. Cordell Bank is adjacent to this
area. On this trip we observed five blue whales, albatross, sunfish. Dall's porpoise, No Response Necessary.
harbor porpoise, elephant seals, northern fur seal, California sea lion, murres, brown
pelican, cormorant, sea gulls, sharks and tufted puffin. The abundance of wildlife in
this part of the ocean is amazing. The waters are "teaming" with these species.

Cordell Bank, being the northernmost sea mountain and the place where the ocean flor
rises from the depths of 1000-2000 feet below sea level to within 140-115 feet of the
ocean surface, allows sunlight to penetrate the ocean surface and produces at the
mountain peak, an environment where a rich variety of benthic organisms live. These
organisms primarily provide the origin of the ocean food chain and feed small bottom
feeders up to large marine mammals. It is very important that this area be protected so
that the ecology of the region will stay intact.

By establishing this area as a Sanctuary, this proposed area would be surrounded by a
perimeter which would protect it from hazards of city pollution and potential offshore
oil drilling which unfortunately for the California coast could be a potential disaster
for the habitat of the region.
Please take time to review and study this proposal. If possible, make -1rip to
this area and take one of these wildlife/whale watching cruises so t e
personally what is in our oceans. Thank you for your attention.

Sincerely,

KAREN A. MENDELOW'
cc: Edward Wilczynski, Acting Chief, Ecology & Conservation Division, US Dep rce@
cc: Whale Center

October 07, 1987

Ms. Vickie Allin
1825 Connecticut Ave.
Washington D.C. 20235

Dear Ms. Allin,

I would like to express and extend my support for the proposed creation
of the CORDELL BANK MARINE SANCTUARY. I am aware, as are many people,
of the devastating effects offshore oil drilling would have on the
marine life and enviornment.
@
Ifurther support both the formation of BOUNDARY #1 in hopes of proid- I- See Generic ResPonse A.
ng the broadest area of protection, and a ban on all offshore oil
drilling activity including leasing, exploration and developement 2. See Generic ReSPOnse B.
within the Cordell Bank Marine Sanctuary.

Sincerely,
A. P. llletoye@@-
kO L7,4
9101112J4,:"\

,V* ')

ora- < aa@dKl A& 0" /4AA

1. See Generic Response A.

2. See Generic Response B.

Aga

OF8; @10
OCT

CA YY11-

5210 Gates Rd.
Santa Rosa, CA 95404
Oct. 4, 1987

Ms Vickie Allin, Acting Chief
Marine and Estuarine Management Division, OCRM
National ocean Service/NOAA
1825 Connecticut Ave., NW
Washington, DC 20235

Dear Via Allin,

I am writing to urge your support in creating the proposed
Cordell Bank National Marine Sanctuary.

I also support Boundary Alternative #1, providing the
broadest area of protection. 1. See Generic Response A.

I strongly support inclusion of a ban on all offshore
drilling activities, including leasing, exploration, and dev-
elopment, within the Cordell Bank Sanctuary from the beginning. 2. See Generic Response B.

There is a tendency among some people to characterize
Californians as heavy drivers who use a disproportionate amount
of our nation's fuel. I assure you that we and our conservation-
ist friends do not ftt that picture at all. Although we live
in the country at some distance from services we need, we plan
carefully to avoid making more trips than necessary. Our son
who works in San Francisco regularly uses public transit. It
may well be that much of our state's fuel consumption is by
visitors from other states, who understandable travel many
miles while here to see points of interest, and by business
people from other states who bring or rent cars to conduct
their business here. Thus I object to Californians being
asked to subject our coast, with its irreplaceable natural
beauty and wildlife, to oil drilling. To subject the Cordell
Bank, our richest fishery, even, to exploration for oil would be
to destroy it and the jobs of those livelihood depends
on it.

Thank you for listening to my concern.

- -------
VEry truly yours,

8 October 1987

Ms. Vickie Allin, Acting Chief
Marine and Estuarine Management Division
office of Ocean and Coastal Resource Management
National Ocean Service/NOAA
1825 Connecticut Avenue, N.W.
Washington, D.C. 200235

Dear Ms. Allin,

I am writing to you today concerning the proposed National Marine Sanctuary for Cordell
Bank (adjacent to the Farallon Islands National Marine Sanctuary in California).

Being a member of Cordell Bank Expeditions, I have made numerous dives on the Bank and
have been fortunate to witness the profuse and unique marine life which inhabits this
underwater oasis.

Also, being an underwater photographer and marine biologist, I have sadly witnessed the 1. See Generic Response A.
destructions caused by offshore oil drilling and oil spills. I appeal to you to support
Boundary Alternative #1 (which includes the waters surrounding Cordell Bank), and to
include provisions for a complete and total ban on ALL hydrocarbon activity within the
sanctuary boundary, as is the case with the other two California National Marine 2. See Generic Response B.
Sanctuaries. I argue you to include these provisions in the sanctuary designation
document at the outset.
Further, I hope you will recommend that additional funds be designated for supporting on- 3. See Generic Response G.
site monitoring, and that provisions for enforcing the regulations be amended to include a
ban on all contact with the shallow ridges (such as anchoring). 4. See Generic Response D.
On behalf of myself and future generations, I thank you for your support.

Sincerely,

Ric ard R. Moore
@
A
d@
B
1,
s'
S
d

1984 Jonathan Avenue
San Jose, CA 95125

cl
Off W
CRICUM
6@z 8z

1. See Gezk'xic ResPIM, B.

N o A P.,
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Ie, 3
Cn

Xt2
1. See Gener
ic Response A.

3 2. See Generic Response B.

U.S-
'0 @, V"T.,

September 29, 1987

Ms. Vickie Allin, Acting Chief
Marine & Estuarine Management Division
Office of Ocean & Coastal Resource Management
National Ocean Service/NOAA
Washington, D.C. 20235

Dear Ms. Allin,
I would like to bring to your attention the proposal con-
cerning the Cordell Bank National Marine Sanctuary. I support
this proposal 100 percent. You see, there are many sea creatures
such as invertebrates, fish, sea mammals (whales, sea otters,
dolphins and such) and birds that need a healthy place to live.
'these animals don't have much clean safe space left protected
from the harmful activities of man. I am sure that my friends,
the sea animals, would enjoy a nice prolected aquatic atmos-
phere, wouldn't you agree? Seeing as how there has been a lot
of garbage dumping, toxic pollution, oil spills, and damage in
general to the oceanic ecosystem, it would be a nice thing, for
a change, if humans would let these marine creatures live with-
out the harmful interventions of mankind. After all,it is their
ocean and they were there first.
The Cordell Bank National Marine Sanctuary would protect
101 square nautical miles of ocean area, streching from Point
Reyes, Calif. to the Gulf of the Farallones NMS. These waters
support a diverse and abundant arrey of marine life including
many rare and unusual species of invertebrates. There are over
38 varieties of fish and the abundance of marine life provide
the food base for 14 species of marine mammals( including the en-
dangered blue and humpback whales) and 47 species of seabirds (in-
cluding the endangered brown pelican). I feel this fertile marine
habitat deserves protection.
The most important regulations imposed would ban the discharge
of oil and other hazardous materials to the sanctuary (preventing
ocean dumping and similar pollution) ; and deliberate removal or
damage to benthic organisms, with exceptions provided for research
or educational purposes.
As of now the proposed draft excludes offshore oil and gas
exploration and develpoment from only a small core area of the
ordell Bank. The sanctuary is very vulnerable to damage from 1. See Generic Pte@ B.
these activities. I feel that the sanctuary regulations should
be strengthened by prohibiting any offshore oil and gas explor-
If ation and development within the entire sanctuary boundary. I
support strongly the preferred alternative (Alternative #2;Bound-
ary Alternative #2) to designate this sanctuary and protect its
7. Lfragile marine ecosystem from adverse human activities. 2. See Generic Response A.
Thank you for your time, and I hope that you will support the
Xordell Bank National Marine Sanctuary. Please send response.

Concerned Citizen Sincerely
Nicole L. Nicola bl'
1816 62nd St.
Berkeley, CA 94703

M. L. Nunes
2046 Leese Lane
Novato, CA 94945
Oct 10, 1987

Ms. Allin,

I am writing this letter to you in regards to the designation of Cordell
Banks' CA :sa a National Marine Sanctusry. I feel that it is imperative
that he ;r boundary #1 be established for the protection of this very
@ nique and pristine area. I wish to express my adamant desire the the 1. See Generic Response A.
entire area have a ban on all hydrocarbon activity. I cannot emphasize
enough the importance of the ban. One only needs to see some of the 2. See Generic Response B.
photographs and video of the underwater area to see how fragile this area
is, and see how detrimental to the area that would be possible should
hydrocarbon activity be allowed. I must insist that as a concerned American
citizen, this area receive the entire support you can give it in this
direction. I will do everything in my power to see that this area be
protected. A great number of my friends and relatives feel the same way. 3. See Genexic Response G.
rwe completely support the Area Designation Boundary No. 1, and a ban
all @'d rocarbon activity, and further request that additional funds
Cor -dLte monitoring, and that provisions for enforcing the regulations
be Zes d to include a ban on all contact with the shallow ridges (such 4. See Generic Response D.
s anchoring). We will do all that we can to fight for these recommendations
and additional funding as necessary to preserve this beautiful area.
Thank you.

Sincerely,

Olt
All)

October 07, 1987

Ms. Vickie Allin
1825 Connecticut Ave.
Washington D.C. 20235

Dear Ms. Allin,

I furthersupport both the formation of BOUNDARY #1 in hopes of proid- 1. See Generic Response A.
ing the broadest area of protection, and a ban on all offshore oil
[.drilling activity including leasing, exploration and developement 2. See Generic Response B.
ithin the Cordell Bank Marine Sanctuary.

Sincerely,
I

Novak

v ztj-t- 2 7, 2,F- 7

k@, C, ;2 0 R,3 -r

10 tv-Z f-, 6:,

1 See C-Wieric

2- Se@- Generic Rep,,,

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41wl OL
61Qall
bc.

A,.,Pwj- c@CJ6

cz No P4sP"Ze MeCessary.

September 28, 1987

Ms. Vicki AZZin, Acting Chief
Marine and Esturine Management Division
Office of ocean and Coastal Resource Management IS
1825 Connecticut Avenue, N.W.
Washington, D.C. 20235 J-

Re: Cordell Bank National Marine Sanctuary CIP

Dear Ms. Allin:

I am writing to comment on the draft environmental impact
statement, draft management plan and proposed rule for the
Cordell Bank National Marine Sanctuary. I would like to
express my strong support for Alternative #2, Boundary
[Alternative #2 to protect this sanctuary and its fragile marine 1. See Generic Response A.
values.

It seems pixilated to designate an area as a marine sanctuary
and not ban oil drilling and ocean dumping right up front.
The recent spill in the channel Islands only serves to illustrate
our inability to deal with even a small incident. Sanctuary
egulations should be strengthened to prohibit any off-shore
Cril and gas exploration and developement within the entire 2. See Generic Response B.
sanctuary boundary.

Why have a sanctuary at all if it is not going to protect
natural resources? The Cordell Bank and surrounding waters
constitute a vigorous ecological community and should be
allowed to flourish unchanged except by Mother Nature.

Sincerely yours,

Ms. Karol Rayl-I
950 Vernal Avenue
Mill Valley, California 94941

KRlhtw
cc : Mr. Edward Wilczynski
The Honorable C. William Verity, Jr.
Senator Alan Crvnston
Senator Pete Wilson
Congresswoman Barbara Boxer

October 07, 1987

Ms. Vickie Allin
t825 Connecticut Ave.
Washington D.C. 20235

Dear Ms. Allin,

I further support both the formation of BOUNDARY #1 in hopes of proid- 1. See Generic Response A.
ing the broadest area of protection, and a ban on all offshore oil
drilling activity including leasing, exploration and developement 2. See Generic Response B.
, within the Cordell Bank Marine Sanctuary.

Sincerely,.

Linda Reid
Novato, C.A.

Ms. Vickie Allin, Acting Chief
Marine and Estuarine Management Division, OCRM
National Ocean Service/NOAA
1825 Connecticut Avenue, N.W.
Washington, D.C. 20235
October 9, 1987

Dear Ms. Al I In,
1. See Generic Response A.
I am writing to express my strong support for creation of the Cordel 1 2. See Generic ReS@ B.
Bank National Marine Sanctuary. Please support "Boundary Alternative * 1'.
Please also Include a ban from the start on offshore oil drilling In this
sanctuary.

This very rich area of marine life deserves the very stiffest protection
we can provide. Thank you for your consideration.

Sincerely,

Martha L. Roberts
978 Santa Ana
Santa Rosa, CA 95404

cc: Mr. Edward Wilcynski, U.S. Department of Commerce 01415ft,'jA

lit

October 07, 1987

Ms. Vickie Allin
1825 Connecticut Ave.
Washington D.C. 20235

Dear Ms. Allin.

I would like to express and extend my support for the proposed creation
of the CORDELL BANK MARINE SANCTUARY. I am aware, as are many people,
of the devastating effects offshore oil drilling would have on the
marine life and enviornment.
@
Ifurther support both the formation of BOUNDARY #1 in hopes of proid- 1. See Generic Response A.
ing the broadest area of protection, and a ban on a11 offshore oil
d
rilling activity including leasing, exploration @nd developement
ithin the Cordell Bank Marine Sanctuary. 2. See Generic Response B.

nc
)11.@yer

<00) -i24@

iI: "T IRY
2555 LeavenwortilR81:9i 28 P 31
San Francisco, CA 94133
September 25, 1987
Ms. Vickie Allin 7()CJ146
Acting Chief
Marine and Estuarine Management Division
Office of Ocean and Coastal Resource Management
National Ocean Service / NOAA
1825 Connecticut Avenue, N.W.
Washington, D.C. 20235

Re: Cordell Bank National Marine Sanctuary

Dear Ms. Allin:

With respect to the draft environmental impact statement, 1. See Generic Response A.
draft management plan, and proposed rule for the Cordell Bank
National Marine Sanctuary, I wish to go on record as strongly
upporting Alternative #2 and Boundary Alternative #2 designating
this area as a sanctuary and preserving it from the effects of
drilling, dumping and other harmful interference so that we and
our children can benefit from its unique opportunities to 2- See Generic ReSpanse B.
preserve a marine ecology, study that ecology, and simply take
pleasure in observing its unimpaired continuity. I further urge
that the sanctuary regulations be strengthened to'promote these
ends by prohibiting any off-shore oil and gas exploration and
development within the sanctuary boundary.

sincerely,

Marie L. Roehm

cc: Mr. Edward Wilczynski
Acting Chief
Ecology and Conservation Division
Room 6814
U. S. Department of Commerce
@N
t
d

Washington, D.C. 20230

The Honorable C. William Verity, Jr.
Secretary of Commerce
U. S. Department of Commerce
Washington, D.C. 20230

Senator Alan Cranston
Senator Pete Wilson

J. Hawkeye Rondeau
P. 0. Box 620458
Woodside, Ca. 94062
October 10, 1987
408-374-3027

%a. Vickie Allen, Acting Chief
Marine and Estuarine Management Division
National Oceanic and Atmospheric Administration
1825 Connecticut Avenue, N. W.
Washington, D. C. 20235

Dear Me Allin,

After a thorough review of the Draft Environmental Impact
Statement and Management Plan for the proposed Cordell Bank
National Marine Sanctuaryv I have concluded that the Plan
has the following shortcomings.

1. On page 42 the possibility of limiting future OCS
leasing to within one silo of the fifty-fathom inobath seem&
terribly short sighted especially in view of recent oil 1. See Generic Response A.
&pill events (i.e., Puerto Rican, Apex Houston) in the
nearby Gulf of the Farallon*& Sanctuary as well am the even
more recent &pill from the Pac Baroness in the Channel
Islands HNS area. I feel that a such larger buffer zone is
necessary because, an we all learned so wall in October and
November of 19a4, very few &pill& evolve am predicted nor
can they be controlled despite the beat possible
"contingency plan".

If this provision cannot be established at this time, then 2. See Generic Response B.
:
t the very least, a complete ban on all hydrocarbon
ctivitisa within the Boundary Alternative 01 should he
contained in the sanctuary designation document.

2. The preferred Management Alternative 02, despite the
obvious economic considerations, is not adequate to provide
for the needs of the vast benthic flora and fauna found at
the proposed sanctuary area. The present management and
*search plans for the Gulf of the Farallon*& Sanctuary has
so far devoted very little time and money for research of
Invertebrate phenomena; why should one suppose that they
wi now a apable of assuming vast now responsibilities in 3. NOAA has spent the majority of its research resources on invertebrate
this arena? Perhaps a now staff specialist position should research an Cordell Bank- An excellent review Of the benthic flora and fauna
b crested to fill this void in the proposed "Tandem" has been provided by NQAA sponsored research on the Bank and is documented n
S:nctuary Managenent-Adainistration Plan. Published research reports and articles. NOAA 1-ntends to jj@ this baseline
Information to better Understand the Structure and functions of the Cordell
In addition, because of my exposure to the rare and vast and Gulf of Farallones ecosystems for future management purposes.
biotic assemblage at the Cordell Banks, I would also urge
,you to designate additional funds for on-.ito monitoring and 4. See Generic Response G.
amend the enforcement provisions to include a ban on all
mooring contacts with the shallowest ridge& where benthic 5. See Generic Response D.
organisms are found in their greatest densities, as noted on
page 22. U
'90900 @40%%
J. Hawkeye Rondeau, Ph.D. iN N
but

';ee Ger@-rC Ples@ A.
2. See GeMriC Respo,_

ANI.

2@) 1. See Generic Response A.

2. See Generic Response B.

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Lvr
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vo t- Ptclb -v 'k 2. see Generic Response B.
66-

LauTette Schorcht
1344 Clavton
San Fraiihsco. CA 94114

~4q>
~c~c
~S~-~p~t~q-~q4~4qf~4qi~- 1987

Me. ~V~i~cI~d~e A11~1~n. Acting ~Chi~s~t
Marine And ~E~at~u~s~qA~n~o ~Y~l~a~m~a~g~qm~ent Division
Office of ~Oc~e~a~m and ~Co~m~q@~st~sl R~e~qmu~qm~e Ma~n~a~g~e~m~o~s~at
~H~a~t~i~'~qm~a~l Ocean ~s~e~rvi~o~4qO~N~O~&~A
~1~8~2~q5 ~C~o~n~n~ecti~out:Av~e~nu~e. ~NW
Washington. DO 202~q3~0

Roo Cordell Bank X~at~io~n~a~l Marine ~L~i~a~n~ct~u~ar~y

Dear Ms. An~in~s
~e~tr~o~m~s support for the ~pr~qefe~r~r~-~0 ~alt~g~r~n~at~ive ~q(~A~l~t~e~qm~a~t~iv~e 1. See Generic Response A.
~iv~e A. 1 a~a opposed to any off-shore oil and gas
o~;~m~en~t within the whole sanctuary boundary. 2. See Generic Response B.

~7h~e Cordell Bank National Marine Sanctuary supports a diver~q" a~md abundant
variety of ~P~aR~vin~e creatures. They should be given a~l~l the p~rot~-~o~ot~i~on
possible to ~s~a~m~i~s~t then In their survival,

sincerely,

(Miss) Damn* Schulte
~q3~q3~1~+ ~r~%~L~zk Street
San Tz~o~n~a~i~m~o~o~, CA 9~4110

o~c too ~'~,~I~r. ~N~i~v~ard ~W~i~l~a~z~y~n~s~k~i~f The ~o~n~o~z~Rbl~e ~qc~. William "1 ~0 ~1~-~
Senator Alan ~Cr~a~m~st~o~n~s Senator ~F~e Wilson and the honorable ~anay ~F~el~o~si

7, V_4

3
By
4r - a

9@4

3. See Generic Respatise A.

2. see Generic Response B.

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11293 R005EVEL~T DRIVE GRAS5 VALLEY, CALIF. 95945

PHONE (916) 273~-4150
Ms. A~L-~L~i~4qu~l

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~r~,~qX~0q@ So ~I~-~q0~q0~C, ~q-~t~(~:~> ~0qE~C~S~TA~qU~;L~c~q9~-~q4, ~qS~c~@ ~i~o ~0qTt~4~j~@~, ~qA~>~E~qS~qP~C~-~-~-~7~'
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~2qD~f~q@~P~,~qC~- ~0qM~qET~qS ~@~qS~qH~O~qUL~8qD ~0qG~4qE ~8qe~4qA~t~J~W~qED if,) ~6qT~@4~qC- P~2qRO~qPO~Z~-~qED

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~6q6~8qw~c~-T~U~qA~4qP~-~le~. ~8qZ~qo~qO~qM~C~qA~I~Z~Y AU~T~qF-~qRIJ~-~,~6qW~)~qU~qF~- 1~1~6 7~1~q4E ~qO~M~L~qY
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~6q2~q0~8q"~I~qS TO ~qCT~' ~4qA~0qQ~q0~6qM 7~qt~q4~8qF- ~q0~4qF OIL 4. See Generic Response B.
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~96q)
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IN T~2qR~qE ~l~qP~qG~2qW~2qE~k~qZ ~q@~q3~0q0~4qH~6qB~2qE~qP~qS OF ~6qP~6qS~4qH C~6qA~qQ~8qG~qA~-~qT~,~(~q3~qQ ~'~T~tA~qE
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Lori Talbot
20 Holcomb Ct.
Walnut Creek, CA 94596

Mr. C. William Verity, Jr., Secretary Designs
United states Department of Commerce
Washington, D. C. 20230

October 8, 1987

Dear Mr. C. William Verity, Jr.,
I would like to express my support for Boundary Alternative 1. See Generic Response A.
I desire a complete and total ban an ALL hydrocarbon activi
within the sanctuary boundary, and Insist that these provisions 2. See Generic Response B.
be included in the sanctuary designation document AT THE OUTSET.
I recommend that additional funds be designated for supporting 3. See Generic Response G.
on-site monitoring, that provisions for enforcing the regulations 4. See Generic Response D.
b amended to include a ban on all contact with the shallow
ridges (such as anchoring).

I have seen this beautiful place with my own eyes (yes, as a
diver!) and believe it to be an extraordinarily rich benthic
community of life; the home of very rare and unusual species of
hydrocorals, sponges, scallops, and snails, with an abundance of
fish, and other (some endangered) marine life.

I strongly support Sanctuary status for the Cordell Bank area,
and recommend that the OCS ban be extended to include the whole
Sanctuary, not just the core area.

Please help us prevent the offshore oil and gas exploration and
development that would change, destroy, and mutilate any of the
Cordell Bank Marine Sanctuary.

Sincerely,

LLORI TaLBOT

Diver, Publications
(415)930-7227

CORDELL BANK EXPEDITIONS
4295 Walnut Blvd., Walnut Creek CA 94596

Erica Tanner
414 William Ave.
Larkspur, CA. 94939
October 2, 1987

Ms. Vickie Allin, Acting Chief
Marine & Estuarine Mgmt. Division, OCRM
National Ocean Service/NOAA
1825 Connecticut Ave., N.W.
Washington, DC 20235

Dear Ms.Allin:

I am writing in support of the creation of the Cordell Bank National 1. See Generic PZesponse A.
Marine Sanctuary. I feel that "Boundry Alternative #111 is the only one
that would effectively protect the area from possible off-shore oil drilling.

I am strongly against the extension of oil drilling off the California 2. See Generic Pasponse B.
coast in general, but in particular, I am opposed to any exploration or
7, development within the Cordell Sanctuary.
I urge you to do what you can to prevent further oil exploration in this
area and to create the Cordell SaRctuary.

Sincerely,

Erica Tanner

1987

October 07, 1987

Ms. Vickie Allin
1825 Connecticut Ave.
Washington D.C. 20235

Dear Ms. Allin,

I further support both the formation of BOUNDARY #1 in hopes of proid- 1. See Generic Response A.
ing the broadest area of protection, and a ban on all offshore oil
drilling activity including leasing, exploration -@nd developement 2. See Ger@ic Response B.
'ZI within the Cordell Bank Marine Sanctuary.

Sincerely,

@'.ichard Tanner

[email protected] VcK,C- qa

777115

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October 07, 1987

Ms. Vickie Allin
1825 Connecticut Ave.
Washington D.C. 20235

Dear Ms. Allin,

I would like to express and extend my support for the proposed creation
of the CORDELL BANK MARINE SANCTUARY. I am aware. as are many people,
of the devastating effects offshore oil drilling would have on the
marine life and enviornment.
I
I further support both the formation of BOUNDARY #1 in hopes of proid- 1. See Generic Response A.
ing the broadest area of protection, and a ban on all offshore oil
drilling activity including leasing, exploration and developement 2. See Generic Response B.
within the Cordell Bank Marine Sanctuary.

Sincerely,

Kris ten Thomas

Bruce E. Walker
4333 Holden St.
Emeryville
CA 94608

October-9,1987

Ms. Vickie Allin
Acting Chief
Marine and &-tuarine Management Division
Office of Ocean and Coastal Resource Management
National Ocean Service/NOAA
1825 Connecticut Ave,
N.W. Washington. D.C. 20235

Re: Comments on the draft enviornmental impact statement, draft management
plan, and proposed rule for Cordell Bank National Marine Sanctuary.

Dear Ms. Allin:

I would like to express my strong, but qualified, support for the preferred
alternative (Alternative @2) to designate this sanctuary, and protect it's 1. See Generic Response A.
fragile marine values. I would however, request that the sanctuary
regulations be strengthened by prohibiting say off-shore oil and gas 2. See Generic Response B.
exploration and development within the whole sanctuary boundry.

I am a concerned citizen and a bird watcher. I know that this very unique
area of the Pacific Ocean should not be invaded by the oil and gas companies
for the purpose of exploration or drilling for profit. Please protect this I
unique sanctuary with all the power of your authority.

Sincere thanks,

lker

C.C.
Mr. FAward Wilczynski
The Honorable C. William Verity Jr
S:nator Alan Cranston
5 nator Pate Wilson
Congressman Ronald Dellums

September 29, 1987

Ms. Vicki Allin
Acting Chief, Marine & Estuary Management Division
office of Coastal Resource Management
National Ocean Service
1825 Connecticut Avenuer N.W.
Washington, DC 20235

Re: Designation of Cordell Bank National Marine Sanctuary

Dear Ms. Allin,

I am writing to comment on the draft environment impact statement, managment plan
rand Pro sed rule for the Cordell Bank Sanctuary. After reading it, I am strongly
. favorof the Alternative Two, Boundary Two Alternative which will designate this 1. See Generic Response A.
r7areaa completely protected sanctuary. However, I must urge that stronger measures
@,'Ie added to prohibit oil contamination of this fragile environment. Having studied 2. See Generic Response B.
marine'biology in college and having kept abreast of current research in marine
biology, I know how devastating oil contamination can be to any area where a
delicate balance in a small area exists. Oil exploration and drilling should be
completely prohibited from the entire sanctuary area to ensure the safety and
continued productivity of the Cordell Bank.

Yours truly,

Anita L. Velazquez
2237 Filbert Street
San Francisco, CA 94123

cc; Edward Wilczynski, U.S. Department of Commerce, Ecology & Conservation Div.
C. William Verity, Jr,, Secretary of Commerce
Senator Alan Cranston, California
Senator Peter Wilson, California

/4@

All

o"elyt
ye@

rl(-,Vl 4Ae77

Z6
14A4(v,@ 1. see Generic PCespouse A.
2, See Generic Response B.

J4,

v)q Id,4,v A@F <
A ftfl,

Ms. Vickie Allin, Acting chief
Marine and Estuarine Management Division
Office of ocean and Coastal Resource Management
National ocean Service/ NOAA
1825 Connecticut Avenue, N. W.
Washington, D. C. 20235
Tel: (202) 673-5122

October 8, 1987

Dear No. Allin,
[I would like to express my support for Boundary Alternative #1. 1. See Generic Response A.
I desire a complete and total ban an ALL hydrocarbon activity
within the sanctuary boundary, and insist that these provisions 2. See Generic Response B.
be included in the sanctuary designation document AT THE OUTSET.
i
I recommend that additional funds be designated for supporting 3. See Generic Response G.
on-site monitoring, that provisions for enforcing the regulations 4. See Generic Response D.
b amended to include a ban on all contact with the shallow
ridges (such as anchoring).

I strongly support Sanctuary status for the Cordell Bank area,
and recommend that the OCS ban be extended to include the whole
Sanctuary, not just the core area.

Please help us prevent the offshore oil and gas exploration and
development that would change, destroy, and mutilate any of the
Cordell Bank Marine Sanctuary.

Sincerely,

0a I'

October 07, 1987

Ms. Vickie Allin
1825 Connecticut Ave.
Washington D.C. 20235

Dear Ms. Allin,

I would like to express and extend my support for the proposed creation
of the CORDELL BANK MARINE SANCTUARY. I am aware. as are many people,
of the devastating effects offshore oil drilling would have on the
marine life and enviornment.
I further support both the formation of BOUNDARY #1 in hopes of proid- 1. see Generic Response A-
ing the broadest area of protection, and a ban on all offshore oil
See Generic Response B.
drilling activity including leasing, exploration d developement 2
within the Cordell Bank Marine Sanctuary.

Sincerely,
Barbara Wishom

185 Rainier Cir.
Vacaville, CA 95688
Getober 7, 1987

Ms. Vickie Allin, Acting Chief of the
Marinie and Estuarine Management Division of the
Office of Ocean and Coastal Resource Management
National Ocean Service/NOAA
Washington, D. C. 20235

Concerning the draft environmental impact statement, draft manage-
,ment plan, and proposed rule for the Cordell Bank National. Marine
Sanctuary: I strongly support the preferred alternative
(Alternative #2; Boundary Alternative #2) to designate this sanct-
nary and protect Its numerous species of marine life.
1. See Galeric Response A.
Because of its extraordinary combination of sunlight penetration,
nutrients upwellings, and ocean currents, Cordell Bank supports many
kinds of marine creatures ' ranging from tiny cy-astaceans to the
Blue whales and Humpback whales (both the Blue whale and the
Humpback Whale are listed as "endangered" in the federal
Endangered Species Act, and are federally protected,* Addition ally,
I respectfully urge that the sanctuary regulations be strengthened 2. See Generic Response B.
by prohibiting any offshore oil and gas exploration and develop-
E ment, and any ocean dumping.
Looking forward to your earliest possible reply on this urgent
matter, I am

Sincerely.

Tamara Wright

cc: Mr. Edward Wilczynski, Acting Chief of Rcolog]t and Conservation
Division of the U. S. Department of Commerce; The Honorable
C. William Verity, Jr., Secretary of the U. S. Department of
Commerce; Senator Alan Cranston; Senator Pete Wilson; The
Honorable Vic Fazio, U. S. Congressional Representative

N611121310
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OCT 197

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1. See Generic Re-cponse A.

2. See Generic Response
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2. See Generic Ptespormp- B.
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ANIMAL
PROTECTION
INSTITUTE
OF AMERICA.

6130 Freeport Boulevard
P 0 Ed, 22505
Sacramento, CA 95822
(916) 422 921
TWX 910 367 2375 API SAC

October 9, 1987

Ms. Vickie Allin, Acting Chief
Marine and Estuarine Management Division
Office of Ocean and Coastal Resource Management,
National Ocean Service, NOAA
1825 Connecticut Ave, N.W.
Washington, D.C. 20235

Dear Ms. Allin:

On behalf of 160,000 members of the Animal Protection
Institute of America, I wish to go on record with our strong 1. See Generic Response A.
support for the Preferred Alternative (Alternative #2, Boundary
Alternative #2) for the Cordell Bank National Marine Sanctuary.
We feel the sanctuary regulations need to be strenthened by 2. See Generic Response B.
including the prohibition of any offshore oil and gas exploration
and development within the sanctuary boundary.

Such areas are notable for their vast richness and biodiversity.
Along the Pacific Coast, there are relatively few of these offshore
seamounts which are so important as areas of nutrient upwelling.
The variety and numbers of seabirds and marine mammals found there
highlights the importance of keeping these special areas free from
the threat of pollution.

Thank you for allowing us the opportunity to comment on the
Cordell Bank National Marine Sanctuary. it is our hope that areas
like this will remain pristine.

FOR THE ANIMAL PROTECTION INSTIUTE OF AMERICA

Sincerely,
OLT

Bruce Webb
Director, Program Services
BW/bms

Chairman of the Board, KENNETH E GUERRERO, Vice Chairman, DUF FISCHER. Secretary, LUANA GRIMLEY. Directors: COLETTE C FAE

GWENDOLYN MAY. ROWLAND MITCHELL. RICHARD WEMPE, Honorary Vice President: KIM NOVAK, National Advisory Board: ROBERT BROWN, Fa
Farming.MERRILL A BURT. D V M. Veterinary Medicine, NED BUYUKMIHCI, V M D Institutional Veterinary Medicine DONALD E DOYLE MD Me
Science Advisor, BRUCE MAX FELDMANN. D V M, Veterinary medicine and Pet Population, MARJORIE GUERRERO, Humane Education MRS KA
HARRISON, Northwest Regional Activities, SHIRLEY MCGREAL, PH D Primate Specialist JOYCE S A TISCHLER JD Animal Rights and the Law, ANN VOL
Promotions and Auxiliaries, MRS. RALPH YOUNGDALE, Publicity and Promotions Foreign Advisors: ANGUS O MCLAREN, Transvaal, South Africa, MRS AJ
MUMFORD, Vancouver, Canada, MICHAELA DENIS, Narrator, Kenya, In Memoriam: VELMA "Wild Horse Annie" JOHNSTON, HARRY DEARINGER, &
FRANK V BRACH CHARLOTTE L B PARKS, CLAUDE, COUNTESS OF KINNOULL

GENEVA. SWITZERLAND
STUTTGART, GERMANY
TORRONTO, ONTARIO

ALL CONTRIBUTIONS ARE DEDUCTIBLE FOR INCOME AND ESTATE TAX PURPOSES

1. see Generic Response A.

2. See Generic Res@se B.

4e,, A-,-

at4,, -7A-4@

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BODEGA BAY AREA CHAMBER OF COMMERCE

BODEGA BAY P.O@ BOX 146
BOOEGA BODEGA BAY, CALIFORNIA 94923
VALLEY FORD PHONE: 875-3422

October 9, 1987

Phil Williams
Project Manager
Marine and Estuarine Management Division
office of Ocean and Coastal Resource Management
National Ocean Service, NOAA
1825 Connecticut Avenue, NW, Suite 714
Washington, DC 20235

Dear Mr. Williams:

The Bodega Bay Area Chamber of commerce, at their meeting of
October 7, 1987, voted unanimously to go on record as approving
of the plan to create Cordell Bank as a National Marine
Sanctuary.
1. No Response Necessary.
The Bodega Bay area is vitally interested in this project and
will extend support to aid in its development.

Very truly yours,

Ken Cherrick
President

OCT IV
Awn
Knis

Ca I if ornia A cadeMY of Sciences

Department of _____________________________

9 October 1987

Vickie Allin
Marine and Estuarine Management Division
Office of ocean and Coastal Resource Management
National Ocean Service/NOAA
1825 Conneticutt Avenue, N. W.
Washington, D. C. 20235

Dear Ms. Allin

I am writing to you to comment on the Draft Environmental Impact
Statement for the proposed Cordell Bank National Marine Sanctuary. I
have been active in research, primarily on marine manuals, in the Cordell
Bank - Gulf of the Farallones region since 1976. It is based on my
experience in this area that I make the following comments.

Section IIB (2c) states that 14 species of marine manuals are known
to frequent the waters of Cordell Bank. This was based on information
presented by
Webber and Oooper (1983). However, that number represents
less than half of the species either sighted or found stranded in the 1. See Generic Response A.
Cordell Bank-Gulf of the Farallones National Marine Sanctuary region.
Based on data collected by Farallon Research Associates between 1982
and 1987 the total number of marine manuals sighted or found stranded
in this region is 32. 1 am enclosing a list of the species.

The area between the North Farallon Islands and Cordell Bank is
heavily utilized by baleen whales, in particular blue and humpback whales,
(Both endangered species) for feeding. In previous years we have seen
large numbers of humpback and blue whales in the vicinity of the Farallon
Islands. This year vie have seen a northward shift of the majority of the 2. See Generic Response B.
whales to the area between the North Farallon Islands and just north of
Cordell Bank. There seem to be considerable movement of whales between
the current Gulf of the Farallones National Marine Sanctuary and the
proposed Cordell Bank National marine Sanctuary. It is for these reasons
that I strongly recommend that Boundry Alternative #1 be chosen.

Fur seal and sea otters ut_-,@ almost entirely upon their fur to
insulate them from the cold North Pacific waters. Fouling of the fur
of either species would, most likely, result in death. Northern fur
seals are regularly sighted in the Gulf of the Farallones and/or Cordell
Bank and the California sea otter has recently been recorded in the Gulg
of the Farallones. Sea birds depend on a layer of air trapped between
their feathers for thexmoregulation. Matting of the feathers, like the
matting of the fur of marine mammals, would destroy the thermoregulating
capacity of the feathers, and possibly result in the death of th@ birds.
The Southeast Farallon Island is the largest sea bird breeding site on the
west coast of North America, south of Alaska, and some of these birds may
utilize the area between the Farallon Islands and Cordell bank (inclusive)
for feeding. 3. Research into the number arid distribution of marine mammals is an ongoing and
As a result of the utilization of this area by both marine mwwols Continuous pmject. Since the formulation of the DEIS/MP new data has been
and sea birds, I feel that a complete and total ban on all hydrocarbon received, specifically regarding whale sightings. NOAA will incorporate this
activity within the sanctuary boundries would riot only be appropriate, new data and the provided table into the Sanctuary data base-
but also advisable. In or@ to assure that the regulations . enforced
-1 reccommed that funds be allocated to provide continual monitoring in 4. See Generic Response G.
_the sanctuary.

Finally, in order to protect the rare species of animals that
are found on the ridges of the bank, I suggest that there be a ban 5. see Generic Response D.
51 on all contact with the 3bdges (such as anchoring).
I have been fortunate enough to experience, first-hand, the
richness of Cordell Bank and the surrounding area. I feel it is
our obligation to preserve ULLs area for ourselves and for future
g-ations. U-ik you for g.Lving the opportunity to help in your
efforts to preserve this area.

Sincerely yours,
"'a '7
Isidore D. Szczepaniak

cc: E. Wilczynski
R. Schmieder
C. Verity

Marine m~qm~els~ sighted or found stranded in the vicinity of ~ODrdell Bank and
the Gulf of the Farallo~nes, California, 1982~-1987.

Balaena glacialis right w~t~iale (S~i)
Eschr~icht~ius ro~bustus gray whale ~0qM
Balaenoptera acutor~ostrata. minke whale (B)
B~alaenoptera borealis sei whale (S~i)
B~alaenoptera physalus fin whale (S~i)
Balaenoptera musculus blue w~Male (~B)
~Megaptera, no~q-gliae humpback whale (B)
Berard~ius bairdii Baird's beaked whale ~(S~i)
Ziphius cavir~ostris C~u~vier~'s beaked whale (S~i)
Mescplod~on densirostris dense-beaked whale (~S~t)
~I~v~e~-~scplod~on carlhub~bsi Hubb~'s, beaked whale (~S~t)
Physeter macrooephalus sperm whale (B)
~Y~-gia brev~iceps pygmy sperm whale (~S~t)
~1~bgia sim~is dwarf sperm w~i~iale (~S~t)
De~l~ph~Lnus delphis ~c~c~m~qmn dolphin (B)
Steno bredai~-~nsis rough-toothed dolphin (St)
Steriella c~oerule~oalba striped dolphin (St)
~r~A~w~s~i~o~p~s t~runcatus; bottlenose dolphin (B)
O~rcinus or~ca killer whale (B)
Gra~n~pus griseus Risso's dolphin (B)
Gl~o~bicephala macr~orhynchus pilot whale (B)
Lagenorhynchus~ c~bli~quides Pacific white-sided dolphin (B)
Lissodelp~his borealis northern right whale dolphin (B)
Ph~o~c~Dena phocoena harbor porpoise (B)
P~h~o~coen~oides dalli ~Dall~'s porpoise (B)
~Zal~ophus; ~califor~nianus California sea lion (~B)
~a~m~e~t~o~p~i~u~s j~u~ba~t~u~s northern sea lion (~B)
Call~o~rhinus ursi~nus northern fur seal (~B)
Arctooep~halus t~o~ynsendi ~G~aadalupe fur seal (~S~t)
Ph~o~ca vitulina harbor seal (B)
~Kiroun~ga, an~gustir~ostris elephant seal (B)
~E~r~A~r~ydra lutris ~' sea otter (B)
Si - ~sight~h~v~q of species
St - stranding of ~ie~s
B - both sighting and stranding of species

I. Sz~czepaniak
Farallon ~F~esearch Associates
San Francisco, CA

CA
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G.Iden @,Ae
Not- @1
MARINE Rec,e fio@
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MAMMAL saus.hfo.
Cahforw 94965
CENTER ff] (415) 331 SEAL

October 10, 1987

Vickie Allin, Acting Chief
M;rifie Estuarine Management Division
0 fice of 0 cean Service/NOAA
1825 Connecticut, Avenue, NW
Wa shington, DC 20235

Dear Ms. Allin:

We are writing in response to the draft EIS on the proposed
Cordell Banks National Marine Sanctury PI an. We support the 1. See Generic Response A.
proposal for Cordell Banks to be designated as a marine
sanctuary. We support area #1 as its proposed boundaries. By
supporting the proposed boundary #1, we endorse the connection
this will make between the Cordell Banks Sanctuary and the Gulf
of the Farallones Marine Sanctuary. 2. See Generic Response B.
The c urre nt EIS does not remove Cordell Banks from future
hydrocarbon exploration or development. We highly recommend that
from the very onset, that the proposed sanctuary be designated as
a no activity zone. Even though this area is not currently under
any proposed leasing for oil exploration, future protection of
this area is crucial.
Funding should be included in the EIS for monitoring and
protection of the sanctuary. A patrol/monitor boat should be
appropriated for this area, aside from the one assigned to the
Gulf of the Farallones Marine Sanctuary. An oil clean-up vessel
and equipment should be maintained in Bodega Bay, instead of
being based within San Francisco Bay. Cordell Banks is so far 3. See Generic Response G.
from San Francisco that if a spill should occur during a storm or
foggy day, it could potentially be days before a vessel based in
San Francisco could reach the spill to even begin any clean-up
efforts.
Cordell Banks is an area rich in invertebrate life, as well
as marine mammals, seabirds, and fish. This is an area of
special national significance. We whole heartedly support this
area (proposed area #1) to be designated as a marine sanctuary
and awarded the protection that it deserves.

Sincerely,

V
31415--,
213141,&,
21
p
Jan Roletto ei n Barrett
Curator Ex' utive Director
/.e OCT 1987

Santa Rosa, Calif.
September, 26, 1987

Ms. Vicki Allen, Acting Chief
Marine & Estuarine Management Division
OCRM
National Ocean Service/NOAA
IB25 Connecticutt Avenue, N.W.
Washington, DC 20235

Dear Ms. Allen:

As Co-chair of COAAST (Californians Organized to Acquire Access
to State Tidelands) I'm writing to you to indicate how important it is
that NOAA be supported in its efforts to create a marine sanctuary off
the northern coast of California to protect the the fish, mammals and
seabirds of the Cordell Banks area. The sanctuary is particularly
necessary because the Cordell Bank is the known habitat for two
species of the endangered whale, the blue whale and the humpback
whale. The Brown Pelican and the wonderous short-tailed albatross have
been observed near the Banks.
The Banks, as you undoubtedly know, are a rich source of protein
for the consumers of the nation. The Federal government should
normally be thinking along lines that would lead to their protection
and enhancement. The fruits of the sea in that area are a Federal
reasure. Their harvest provides jobs and spending capital for
hundreds, maybe thousands of people, a fact that should not be 1. see C"Ieric Response B.
forgotten when considerations are advanced by oil companies for
exploration and production permits. Everything seems to have its
ime. It's time for stringent protection of the California Coast lest
we loose its productive environment forever. Please do what you can to
support the establishment of the proposed marine sanctuary.
In conclusion, allow me to say that COAAST is twenty years old
[his year. We are unique in our origin and determined in our cause. In
summary COAAST supports-the Sanctuary movement, opposes further 2. See C-eneric Response A.
seismic exploration and drilling within boundary * I of the
proposed Cordell Bank National Marine Sanctuary.
We thank you for your kind attention.
Sincerely,
a-4,.P@ W.
C. H. Rhine
Co-chair, COAAST

,23
@
h,

co L

Conservation Call, Inc.
ESTABLISHED 1969 7 0 T@3 3

P. 0. Box 87 Sea Ranch, CA 95497 (707) 785-2248

7 October 1987

Ms. Vickie Allin, Acting Chief
Marine and Estuarine Management Division
Office of Ocean and Coastal Resource Management CZ
National Ocean Service/NOAA
1825 Connecticut Avenue, N.W.
Washington, D.C. 20735
Dear Ms. Allin: rq
On behalf of our members, we endorse, with some exceptionst@ha@-'
Draft Environmental Impact Statement for the Cordell Bank National
Marine Sanctuary.
We support Boundary Alternative 1, basically because its size will 1. See Generic Response A.
o
offer greater protection for the Bank. A strict prohibition against any
offshore oil and gas exploration and development must be included. The 2. See Generic Response B.
e preferred Alternative provisions on offshore drilling are so weak
they offer no real protection.

While I was writing this, the news came that Congressman Douglas
Bosco has proposed that oil drilling be allowed in the Arctic National
Wildlife Refuge in exchange for the promise of no drilling on our
Northern California Coast. This proposal is unacceptable and cannot be
put over. The rebuffed oil companies will simply come back to attempt
their assaults on our coast.This is why there must be complete protection
for the Cordell Bank.

Time is of the essence here and we urge speedy designation of the
Cordell Bank National Marine Sanctuary, with Boundary Alternative 1,
containing absolute prohibition against offshore drilling.

Please send us the Final EIS and the Management Plan, when issued.

Thank You

Roscoe A. Poland, Director

cc: Senator Alan Cranston
Senator Pete Wilson
Congresswoman Barbara Boxer
Congresswoman Nancy Pelosi
Congressman Jim Bates
Congressman Douglas Bosco
A.

f
of

Honorable C. William Verity, Jr.
Mr. Edward Wilczynski

As we save the natural world, we also save ourselves.

Expedition Leader: Research Vessel:
ROBERT W. SCHMIEDER, Ph.D. CORDELL EXPLORER

Advisory Committee:
DUSTIN D. CHIVERS, Calif. Acad. Sciences Financial Support:
DANIEL W. GOTSHALL, Calif. Dept. Fish & Game NATIONAL GEOGRAPHIC SOCIETY
i'me
JAMES V. GARDNER, Ph.D., U.S. Geological Survey CONSERVATION AND RESEARCH FOUNDATION
MICHAEL HERZ, Ph.D., Tiburon Cbr. for Environ. Stud. EXPLORERS CLUB
HAL MARKOWITZ, Ph.D.. San Francisco State Univ. NATIONAL OCEANIC AND ATMOSPHERIC ADMIN.
PAUL SILVA, Ph.D., Univ. Calif. Berkeley SAN FRANCISCO FOUNDATION

CORDELL BANK EXPEDITIONS
4295 WALNUT BLVD., WALNUT CREEK CA 945% TEL: (415) 422-2821, 934-3735

Page 1

24 Sept. 1987

Ms. Vickie Allin, Acting Chief
Marine and Estuarine Maanagement Division
Office of Ocean and Coastal Resource Management
National Ocean Service/NOAA
1825 Connecticut Avenue, N. W.
Washington, D. C. 20235

Dear Ms. Allin:

I appreciate this opportunity to provide comments on the Draft
Environmental Impact Statement, Management Plan, and Designation
Document for the proposed Cordell Bank National Marine Sanctuary.

Cordell Bank Expeditions is a non-profit research association
dedicated to exploring and describing Cordell Bank in support of
its protection through designation as a national marine sanctuary.
This project began in 1977, and has involved the efforts of more
than a hundred divers, surface observers, marine biologists and
geologists, and a variety of funding agencies, including NOAA. As
indicated in the draft documents, this organization provided the
primary source material which formed the basis for this
nomination. It is with great pleasure that we see the progress
toward designation, and it is with the background of ten years of
studying Cordell Bank, in the water, in the laboratory, and in the
library, that I respectfully offer these comments.

Ahead of my comments I would like to compliment the work of NOAA,
and particularly the efforts of Mr. Bill Windom in preparing the
draft EIS, draft management plan, and draft designation document.
In general, the documents capture the central reason why Cordell
Bank is special, namely that due to the overlap of several
favorable oceanic and topographic conditions, an exceptionally
productive biological community thrives on the Bank and in the
surrounding waters. The proposal generally identifies the
geographical region with the dense benthic community, and
describes the large populations of fish, birds, and marine mammals
supported by the Bank. It generally provides for managing the
sanctuary and generating public information and research programs.

A non-prafit scientific association. Contributions are tax-deductible.

Page 2

Less clear is whether this plan satisfies the imperative set forth
in the authority to establish marine sanctuaries, Title III of the
Marine Protection, Research, and Sanctuaries Act, as amended, 16
U.S.C. 1431 et. seq.:

"...to designate sanctuaries to promote
comprehensive management of their
conservation, recreational, ecological,
historical, research, educational, or esthetic
values,"

and whether it satisfies the goal enunciated on page 10 of the
draft documents:

"...the highest priority for management is to
protect the marine environment and resources
of the Cordell Bank National Marine Sanctuary
(CBNMS)."

I fear that the draft documents do not provide for comprehensive
management of the CBNMS, and as a consequence do not provide much
protection for its resources. The comments that follow are meant
to stimulate revision of the documents to provide for
comprehensive management that will provide protection for the Bank
and its biological community.

The most significant potential threats are (1) fishing; (2)
hydrocarbon activities; (3) removing or damaging resources.

(1) FISHING

The fishing industry is generally well-regulated, and there are
many well-motivated fishermen concerned with the long-term
stability of the stocks. However, there are many records of abuse
of fishing grounds, presumably by persons other than those just
mentioned. This is relevant to Cordell Bank because we have
received many reports of significantly increased fishing pressure
on the Bank over the past two years. Such reports are supported by
our own field observations in 1986 of significant reductions in
the numbers of rockfish, observed both on the fathometer and by 1. See Generic Response I.
divers. In addition, a 2-year project at the Tiburon Marine
Laboratory has documented a recent decline in the number of adult
rockfish. Many persons have said to me, "...at this rate, there
won't be any fish there in a couple of years..."

Civen this background, and the fact that the fish are among the
most important resources of the Bank, is it right to specifically
exempt the fishing industry from any responsibility within the
sanctuary? Would it be acceptable to establish a sanctuary and
then stand by and watch as its fish are decimated? I am not

Page 3

suggesting that this will actually occur, or that the large
majority of fishermen are not reasonable and responsible. It is,
rather, the unusual, unpredictable, the accidental, the unforseen,
the exceptional circumstance that can creat a threat, and against
which any entity such as a sanctuary should be protected. We
should say, "What if ... " and then have an answer. For instance:

* What if ... someone with high technology equipment (a
"Super-fish-zapper/zipper") suddenly starts taking the rockfish at
Cordell Bank in large numbers, but he searches his catch for the
rare Albino Goby that has magical powers and throws 99% of the
fish back, of which 95% die?

* What if ... someone deploys thousands of traps to capture
juvenile fish (without removing them) because they think that
adult fish will be attracted to the area?

* What if ... someone introduces an entirely new fish on Cordell
Bank that may alter the existing natural balance?

If these scenarios sound far-fetched, just remember what happened
to the Sierra Nevada during the gold rush of 1849, or to the
Farallon Islands rookery when entreprenours discovered the birds'
eggs. We have just come through a crisis relating to gill-netting,
in which large numbers of commercial fishermen were taking
rockfish from Cordell Bank (and other places) in numbers that
threatened extinction. In the case of gill-netting, it Look new
legislation (California Senate Bill SB40) to stop it. The point is 2. NOAA will monitor activities on the Bank that may potentially impact the
that it is predictable that unpredictable situations will arise re_-4xtrces. If the resources are exxiangered then NOAA has 'the authority to
that cpuld threaten the resources; we should have some means for invoke emergency regulations to prohibit specific activities.
t
[dealing with those unpredicted dangers.
There is, in addition, a potential direct conflict between fishing
and Article 942.6 of the prohibited activites in the draft
designation document, namely:

"Attempting to damage, or damaging, or
attempting to remove, or removing, benthic
organisms ..."
3. Benthic organisms are described as those flora and fauna in pemarvent
rAre bottom fish "benthic organisms" (yes, I would say)? physical contact with the ocean bottan. Damersal fish are riot included in
LFurthermore, we have often seen bottom damage from fishing gear this category. NQAA does not intend to regulate fishing or aocidental taking
when diving on the ridges and pinnacles. Every time a lead sinker of benthic organisms during 'the normal course of fishing operations.
hits the bottom, it it very likely to damage something, such as
e (federally protected) California hydrocural. Can you sanction 4. See Generic Responses I and D. Also the California hydroooral All
bottom fishing while still prohibiting damage to the bottom? californi is not a federally or state protected resource. However the
massive density of the coral on Cordell Bank is most unique and deserves the
Although fishing is regulated by many other agencies, those special attention and protection that will be afforded by designation of the
regulations were not designed specifically for special area as a marine Sanctuary.
[environments such as Cordell Bank. The draft document, p. 7,
indicates as much:

Page 4

"...each of these agencies is concerned only
with specific activities, rather than with the
Bank environment as a whole. Designation of
Cordell Bank as a national marine sanctuary
can provide the long-term comprehensive
planning amd management needed to protect its
habitats and ecosystem."

If this is so, why do the documents specifically exclude
regulating, or responding to, fishing, at present THE major
activity on the Bank? It appears to me that the same authority by
which the sanctuary is established not only permits but actually
requires some type of protection. It seems to me that the
"Comprehensive management" clause in Title III and the "highest 5. See Generic Responses G ard I.
priority is protection" goal in the draft documents strongly argue
for some type of control over abnormal fishing activities at
Cordell Bank.

Please note that I am not advocating any restriction, regulation,
or infringement on the normal activities. Indeed, it is well-known
that a major part of my motivation in seeking to have Cordell Bank
protected is to protect the fishing industry, both commercial and
recreational. It is not the normal that we need protection from,
but the ABNORMAL. This is exactly the same situation as with other
activities: it is not the normal activities (it is normal to NOT
dump chemicals on the Bank), but the abnormal activities (dumping
chemicals is abnormal) that are restricted. I see nothing in the
proposed sanctuary documents that can protect the Bank from
abnormal fishing activities, and I recommend inclusion of same.

(2) HYDROCARBON ACTIVMES

My general comments here are similar to the comments on fishing in
the sense that the proposed documents do not go far enough toward
protecting the resources. In this case, however, it is both the
"normal" activities and the "abnormal" events that concern us. By
"normal" activities, I mean the projected lease sales for
hydrocarbon exploration and development in the vicinity of Cordell
Bank, especially in the Bodega Basin. By "abnormal," I mean
unplanned well venting, vessel accident, and the like.
The proposed designation document is very brief on this subject: 6. See Generic Response E.

"Hydrocarbon activities will not be subject to
regulation at this time but MAY be regulated
in the future IF deemed necessary for resource
protection" (emphasis is mine).

Does this mean that such regulation is contained within the
management plan (Section III:B.2(c)? If so, the plan seems at odds
with the spirit of sanctuary designation. The only area protected

Page 5

(with the above MAYJF barriers) is within the 50-fathom isobath,
which contains 18.14/101.10 = 17.96% of the sanctuary area. The
plan calls for monitoring hydrocarbon activities within I nautical
mile of the 50-fathom isobath, but the sanctuary boundary lies 3
nm out; the 2-nm strip surrounding the sanctuary open and
unrestricted for hydrocarbon development.

For your reference I enclose a copy of a profile of Cordell Bank,
with a sketch of an oil rig on the 50-fathom isobath, just a few
hundred yards from some of the shallow ridges. The 50-fathom
contour is Simply too Close to the biologically most productive
areas on the Bank to provide insulation.

All of these comments add up to one central idea: the boundary of
the sanctuary should be larger, and all hydrocarbon activities,
including exploration, test drilling, rigging, piping,
transporting, and storing petroleum based or related materials,
should be totally banned within the entire sanctuary boundary from
the outset.

In this regard, I (and the majority of other persons giving input
at the scoping meeting in 1984 and EVERYONE speaking at the recent
hearings) prefer Boundary Alternative #1. There are many ways to
express this as being the most reasonable boundary for the CBNMS:

* The larger boundary provides insulation from any projected
hydrocarbon activities. It is well-documented that the birds and
mammals utilize the waters around the Bank as well as on the Bank
itself, and that they depend on a large buffer zone to flourish.
On a whale-watching trip a few weeks ago, we found the whales off
the northwest edge of the Bank; they were there because of food
supply determined by the topography and biology of the Bank, but
they weren't "on the Bank."

* One look at the chart of the Gulf of the Farallons National
Marine Sanctuary is enough to convince a reasonable person that
the Cordell Bank area should have been included within that
sanctuary, and this includes the waters around the Bank.

* The proposed Boundary Alternative #2 would be a legal and
management nightmare, By defining a cusp between two sanctuaries,
enforcement of sanctuary regulations becomes an exercise in 7. See Generic Response A.
navigational and cartographic virtuosity. Imagine the legalities
of determining liability if an infraction took place near the
common boundary of the two sanctuaries, where the width of the
.non-sanctuary" region is comparable to the length of a large
vessel!

* Proposed Boundary Alternative #2 would also foster contempt for
the sanctuary. I discussed this with fishermen in Bodega Bay.
Their response was "if you can't tell whether you're inside or
outside it, why worry about it?" Not every vessel is equipped with
satellite navigation. The sanctuary boundary should be simple.

Page 6

The Bodega Canyon, lying to the north and east of Cordell
Bank, is a valuable part of the environment, especially for
fishing. Boundary Alternative #1 would include the canyon, whereas
the other Alternatives would not.

The draft plan (p. 73) indicates that Cordell Bank is currently
excluded from the OCS leasing program, within the 50-fathom
contour, and further,

"if Cordell Bank is subsequently included in
the OCS leasing program sanctuary regulations
establishing a 'no-activity' zone within the
fifty-fathom contour will be CONSIDERED"
(emphasis mine).

But establishment of the regulations, according to Article 6 of
the draft designation document, requires the full legislative
procedure, and would therefore present a substantial barrier to
actually occuring. In addition, deferral of implementation of
regulations until such time as there is a direct threat violates
the spirit and motivation of establishing such regulations. Laws
of all kinds, including regulations, are established AHEAD OF TIME 8. The purpose of the Sanctuary is to provide comprehensive management of a
01 NEED, so that they may be constructed with as little bias and special marine area with coordination of existing management authorities and.
with as much deliberation as possible. Why wait to protect the the proposal of only those regulations r*K:essary to fill the gaps in the
Bank against a hydrocarbon threat until the threat is manifest? existing regulatory framework.
Expressed differently, why prohibit activities such as removing
benthic organisms now, while not prohibiting hydrocarbon
activities until it is "necessary for resource protection"
(documents, p. 102)? If it is your intention to protect the
resources at Cordell Bank from hydrocarbon development in the
future, why not simply write this provision in the above statement
at the beginning:
lr@
"... a 'no-activity' zone ... will be
considered TO BE ESTABLISHED."

Or better still, why not simply prohibit all hydrocarbon
activities within the sanctuary, from the outset:

"942.6 Prohibited Activities
(1) Depositing or discharging materials or
substances
(2) Removing or damaging resources
(3) Hydrocarbon activities." 9. The T/V Ri oil spill was a -violation of the no discharge
prohibition in effect in the Point Reyes-FaLrallon Islands National Marine
Absent this, the imperative to protect the resources appears Sanctuary. With regards 'to emergency regulations, NQhA can regulate
[
0

B,,
E

intentionally frustrated. activities immediately when it is determined to be essential to prevent
immediate, serious and irreve:rsible damage to the ecosystem of an area.
Regarding emergencies, what is to be done about a disaster like Harmful activities can be regulated on an emergency basis for up to 120 days,
the wreck of the Puerto Rican? What happens when the 120 days are during which permanent regulations may be proposed.
up, but oil is still leaking from a hull? Is this the beginning of

Page 7

protracted period to effect an ammendment, or can another
120-period be initiated (which would call the whole idea of a
afixed time period into question)?

Another feature that is missing from the proposed regulations is
the ability to control hydrocarbon development outside the
sanctuary boundary that damages resources inside the boundary. It
is true that the proposed regulation 15 CFR Part 942.6 (a)(1)(B)
prohibits:

... depositing or discharging, from any
location beyond the boundary of the Sanctuary,
aterials or substances of any kind which may
reasonably be expected to enter the Sanctuary
m

and injure Sanctury resources."
But this will not stop damage from hydrocarbon activities, since 10. See Generic Responses B and E.
arguments could be brought that establishment of a sanctuary
boundary carries the implication that the boundary provides
sufficient buffer. But this is manifestly not true, since the
complex currents can be expected to distribute materials in
unpredictable ways. I think the Sanctuary should have built into
it a requirement that any potential hydrocarbon activity in a
broad area be required to demonstrate that it will not injure
resources within the sanctuary.

Provision is made to respond to emergencies, but this is limited
to "an interim period not to exceed 120 days." Article 4, Section
3 of the draft designation document indicates that it is only
possible to provide protection against chronic, or planned,
developments outside the sanctuary that damage resources within
the sanctuary by going through the same process originally used to 11. See Responses at 9 and 10, above.
set up the sanctuary, and that this must be proposed within a
120-day period, presumably to be acted upon later. Since the
present documents took 6 years to produce, and since chronic or
planned development would not normally be considered an emergency
anyway and would therefore not fall under the emergency
regulations, there appears to be no way to prevent damage from
"rydrocarbon activities outside the sanctuary.

I feel very strongly that the situation vis-a-vis hydrocarbon
activities in the area around the proposed CBNMS violates the
spirit of the national marine sanctuary program and the letter of
the Sanctuaries Act. The twin concepts of "comprehensive planning 12. See Generic Response B.
and management" and "protection," so often emphasized in these
documents, appears to be simply ignored in this case. It is clear
that establishment of the sanctuary DF14ANDS protection from ANY
threat, and this includes hydrocarbon activities. I strongly urge
that the documents provide for this protection.

Page 8

(3) REMOVING OR DA14AGING RESOURCES

The draft regulations (p. 107) prohibit:

"Attempting to damage or damaging, or
attempting to remove or removing, benthic
organisms on the ridges and peaks of Cordell
Bank.

I believe that this should be strengthened in three respects:

* ANCHORING. Anchoring creats terrible damage, especially to the
California hydrocoral (which is a key species at Cordell Bank).
This damage is documented in the observations and photographs made
by divers during our expeditions. Anchoring creats a large ring of
destruction due to dragging of the chain. I recommend that the
F"'regulations be written to specifically exclude anchoring on rocky
points, except in emergencies or by permit, leaving anchoring in 13. See Generic ResporLses D and E.
sediment (which is abundant) unrestricted. Generally the sediment
is at 30 fathoms and deeper.

Better would be a provision that any activity that could involve
mechanical contact with the bottom be subject to regulation and/or
LXrmit approval.
CULTURAL RESOURCES. Resources include not only benthic
organisms, but also cultural resources such as artifacts, rocks,
and sediment. For instance, the anchor lost by Edward Cordell when 14. See Generic Response J.
he discovered the Bank in 1869 is a valuable historical artifact,
but would be vulnerable to salvage under the proposed regulations.
The regulation should protect these additional resources from
removal and damage,

DEEPER WATERS. The deeper parts of the Bank, including
diment deposits, also contain significant resources, including
biota. For instance, some of the sediment deposits constitute a 15. See Generic Response E.
chemical supply that could be mined commercially. The regulation
15 st'
should protect all resources within the boundary of the sanctuary,
whether they are on a ridge, peak, or on a canyon, basin, or
anywhere else.

I would favor a broader phrasing of the resources protection, such
I
as:

... Attempting to damage or damaging. or
attempting to remove or removing, or
attempting to frighten or frightening any
material resource, living or nonliving, other
than allowed fishing activities or as provided
by permit, anywhere within the sanctuary
boundary."

Page 9

These remarks constitute my main comments. I can offer several
others on miscellaneous matters:

* EXPLOSIVES AND RELATED ACTIVITIES. Explosives and similar
processes are used for seismic sounding, testing, military
practice, and other purposes. Such activities creat violent noise
in the environment that kills, damages, or frightens organisms.
For instance, hydrocarbon survey ships, called "boom-boom boats"
by the local residents in Bodega Bay, apparently significantly
reduce the catch of rockfish. The same complaint has been voiced
!n the Gulf of Mexico. I would favor inclusion of a
16. Thexe is no apparent need to propose additional prohibitions that would
no -harrassment" provision in the list of prohibited activities, duplicate current State and Federal statutes protecting marine resouroes frown
[alplying to any living organism, not just birds or mammals. activities desCribed. Also, see Generic Re!E@ B.
INTERFERING WITH RESEARCH. Since research is an avowed goal of 17. At present there are no scientific markexs arid NOAA does riot anticipate the
gement of the CBW4S, interference, such as moving, altering, placement of buoys and other research markers on or near the bank. If such
destroying markers, buoys, or instruments, and similar means activities should occur then measures will be enacted, on an ad hoc basis, to
7 [o',r-07concerted study, should be prohibited. protect the research equipnent. Thus there is no rgNed to regulate
* BODEGA RAY. Since Bodega Bay is the closest port, and from interference with research equipuent.
which most boat travel to Cordell Bank take place, I recommend
that the sanctuary provide for a branch manager, office, and
display in Bodega Bay. A full-time staff person in Bodega Bay may
not be necessary, but it certainly seems necessary to have a
representative of the sanctuary on location at least part-tine,
and to provide visitors and residents with an interpretative
display of the sanctuary.
* ENFORCEMENT. The draft documents do not clearly provide for 18. See Geive-ric Response G.
any regular on-site monitoring and enforcement of the regulations.
I would strongly recommend that an officer be provided, in the
same way that one is provided for the Gulf of the Farallons, and
that he make regular rounds of the Bank.

In summary. although I find much laudable in the draft plan, I
feel that in its present form it leaves Cordell Bank vulnerable to
unpredicted fishing pressure, to planned hydrocarbon development,
and to mechanical damage, and I believe that the same Act that
authorizes establishment of the sanctuary also requires the
completion of its protection from these dangers.

Thank you again for providing the opportunity to submit these
comments.

S, I
',t 4.0,,1213 1-,,-
40

OLT

SOP, FA--E 9

I iki @--AA
V)
< . .. . 1. @ I. Cf)
LLI LU

-- 75 r-ATI-40AAS

'De Oers
OF WILDLIFE

October 3, 1987

Dear Ms. Allin:

Defenders of Wildlife submits this letter as our comments and
recommendations with respect to the Draf t Environmental Impact
Statement (DEIS), Draft Management Plan, and proposed rule for
the Cordell Bank National Marine Sanctuary. This letter is
intended to sup lement our verbal testimony submitted at the
September 30 puglic hearing in San Francisco. Please consider
our letter and testimony, and include this letter in the appropri-
ate public record. We appreciate this opportunity to provide input.
At the outset, Defenders of Wildlife generally supports and applauds
this proposed Cordell Bank National Marine Sanctuary. As you know,
Cordell Bank is an undersea "island" of pinnacles and ridges which
reach up to within 140 to 115 feetof.the ocean surface, located on
the edge of the Pacific continental shelf, 20 miles west of Point
Reyes. Due to a unique combination of ocean currents, nutrient
upwellin a, and sunlight penetration, Cordell Bank supports an
incredibly diverse and abundant array of marine creatures. Indeed,
Cordell Bank and surrounding waters constitute a vigorous ecological
community, from small crustaceans and fish up the foodchain to dozens
of seabird and marine mammal species (including blue and humpback
whales). Unfortunately, Cordell Bank is vulnerable to many possible
adverse human activities, s4ch as offshore drilling, tanker spills,
and ocean dumping.

In July 1981, MOAA received a recommendation to establish this
marine sanctuary. About three years later, NOAA sponsored a public
scoping meeting in San Francisco to solicit public comment. We
were represented at this meeting, and we recall substantial, if not
overwhelming, public support for this sanctuary designation. Since
then, it has taken over three additional years for the preparation
of the draft documents now available for comment. We are generally
dis! ointced that it has taken NOAA six years to reach this point
r- 2
n t a an tuary designation process. Given a number of oil spills
off the California coast in recent years, along with proposals for
offshore drilling and ocean dumping, Cordell Bank could have been
@efe@

CALIFORNIA OFFICE: 5604 ROSEDALE WAY, SACRAMENTO, CALIFORNIA 95822 e (916) 442-6386
NATIONAL OFFICE: 1244 NINETEENTH STREET, NW * WASHINGTON, DC 20036 e (202) 659-9510

Oers
WILDLIFE
2.

harmed during these intervening years. We request expeditious com-
pletion of the Cordell Bank National Marine Sanctuary designation.

While we support the Preferred Alternative as far as it goes, we
recommend two reasonable and necessary strengthening improvements.

First, we recommend Boundary Alternative #1. This would establish
a sanctuary area of 397.05 square nautical miles. As indicated on
DEIS page 65, this boundary would include all waters within a line
extending southwest from Bodega Head to the 1,000 fathom depth 1. See Generic Response A.
contour west of Cordell Bank, then around the Bank to the southwest
until it joins the boundary of the Point Reyes-Farallon Islands
National Marine Sanctuary. As stated on page 65, "This alternative,
or a variation of it, was the most frequently suggested in comments
solicited by NOAA at the scoping meeting in April 1984."

We disagree with the reasons described for rejecting this boundary.
For-e-Za-m-pre-, much of Cordell Bank's abundant and diverse marine
life depends upon the unique contribution of ocean currents and
nutrient upwellings. On DEIS pages 18 and 19, the seasonal differ-
ences between the California and Davidson currents are described.
It is clear that there is a complex mosaic of physical forces at
work in maintaining the biological richness of Cordell Bank. We
believe that it is arbitrary and capricious to assume that merely
extending the sanctuary boundary three nautical miles beyond the
50 fathom depth contour surrounding the Bank will provide suffi-
cient protection. Adverse human activities at three nautical miles
could quickly and profoundly affect marine resources on the Bank.

In contrast, Boundary Alternative #1 provides a more logical, manage-
able, and enforceable boundary. It is consistent with most of the
public input received by NOAA. In addition, the DEIS indicates on
page 65 that there is "...no need to protect all of these waters as a
habitat upon which marine mammals depend," given provisions of the
Marine Mammal Protection Act Q-WA). While the MMPA generally pro-
tects marine mammals against physical takings, we are not aware of
any MMPA provision protecting "critical habitat" per se. In other
words, the NNPA may not necessarily preclude harmful human activi-
ties in areas of historic marine manmal importance or concentrations.
Thus, marine sanctuary designation can provide marine habitat pro-
tection not afforded by the MMPA.

We also wish to clarify any confusion with respect to our endorsement
of Boundary Alternative #1. When we first received the draft documents,
we erroneously believed that the Interior Department proposals for off-
shore leasing would not affect the waters proximate to Cordell Bank.
We were also under tFe-false impression that the Preferred Boundary
Alternative #2 may have reflected a compromise reached in consul-
tation with the Interior Department. This led us to initially

Of WILDLIFE
3.

recommend acceptance of Preferred Boundary Alternative #1 to some
of our colleagues and wildlife activists. Upon further study, how-
ever, we learned that the Interior Department's offshore leasing
plans include the proximity of Cordell Bank; indeed, they "surround"
the Ban-k-a-EX-go to the northern boundary of the existing Point Reyes-
Farallon Islands National Marine Sanctuary (please see attached map
entitled "Oil Drilling Proposals for the Cordell Bank Marine
Sanctuary"). We further learned that there is no compromise or
understanding per se with the Interior Department or others with
respect to the Preferred Boundary Alternative #2. In light of these
clarifications, we have decided to strongly support and recommend
Boundary Alternative #1 for the reasons expressed above. We apolo-
gize for any confusion or misunderstanding.
The second strengthening improvement we recommend is an outright
and full prohibition on any offshore oil and gas exploration or
developmen-It-14 Itn t@he whole sanctuary boundary. Given the Interior
Department's leasing pro-p-o-s-als which "surround" the Bank, offshore
exploration and development may pose the most serious threats to
the Bank's natural integrity. We are not reassured that Interior
Secretary Hodel's 5-year offshore leasrn-g plan has removed Cordell
Bank's 50 fathom contour from leasing activities. Offshore leasing
and development could still occur around and near Cordell Bank, and 2. See Generic Response B.
the changing currents in this area could quickly carry drilling
muds, toxic substances, and oil into the Bank. It is equally dis-
tressing that the preferred alternative would simply retain the
option of considering offshore drilling restrictions in the future.
We believe this is a backward and anemic approach. In a terrestrial
context, this approach would be analagous to recommending creation
of a national park or wilderness area without any restrictions on
oil drilling or mining, but merely retaining the possibility of
restricting these activities in the future. Cordell Bank needs and
deserves realistic protection.
As you know, California's two existing sanctuaries at the Channel
Islands and Point Reyes-Farallon Islands both include regulations
prohibiting offshore drilling. These regulations represent a hard-
fought victory over objections from the Interior Department and
oil companies. After the promulgation of these regulations, oil
companies sued in an attempt to invalidate them. Fortunately,
these regulations were upheld during this legal challenge. Sadly,
the preferred alternative in this DEIS is so weak with respect to
offshore drilling, that it is analagous to a boxer "throwing in the
towel" after defeating a challenger. In other words, Cordell Bank
appears equally qualified to receive an offshore.drilling prohibition
comparable to the regulations now in effect for California's other
two sanctuaries.
In conclusion, please work for the expeditious designation of the
Cordell Bank National Marine Sanctuary, with regulations strengthened

Oers
WILDLIFE
4.

to reflect Boundary Alternative #1 and prohibiting any offshore
oil and gas activities.
We would also appreciate a copy of the Final EIS and Management
Plan when they become available.

Thank you very much for your assistance, and for considering our
views.

Sincerely,

Richard Spotts
California Representative
Defenders of Wildlife

RS/ja
Encl. 1

cc: Senator Alan Cranston
Senator Pets Wilson
Congresswoman Barbara Boxer
Congresswoman Nancy Pelosi
Congressman Douglas Bosco
The Honorable C. William Verity, Jr.
Mr. Edward Wilczynski
Jananne Sharpless
Interested parties

OIL DRILLING PROPOSALS FOR THE
CORDELL BANK MARINE SANCTUARY

Bodega Harbor
He
xx@
............ .. . KI
gi 00,
Dillon Beach

------------------------
omales Bay

Marshall

Abbott
Lagoon
-z
K-K-K: Inverne

R.'Reyes
Station
qw- Point Drakes
2%, Reyes Bay

x-,-x
B ligZ;

Fanny Noonday Rock
Shoal*
A, GULF OF THE FARALLONES
fWARINE SANCTUARY

6r%Q!S@ N al Miles
0 5
Qz@-45%2!s@ S tuts MOOS
Depths in Fathoms

Proposed Cordell Bank Interior Department Proposals
National Marine Sanctuary for Offshore Oil Leasing Areas
Proposed Boundary at
,%8ga Ho
Dill,

Proposed Boundary #2

ooo0oQ Proposed Boundary #3

THE EWRONMENTAL FORUM OF NIARIN
P@0, BOX 74
LARKS". CA 94939

A NON-PROFIT CITIZEN GROUP DEVOTED TO EDUCATION IN MARIN COUNTY ON ENVIRONMENTAL MATTERS.
October 10, 1987

Ms. Vickie Allin. Acting Chief
Marine and Estuaries Management Division
Office of Ocean and Coastal Resource Management
National Ocean Service/NOAA
1825 Connecticut Avenue, N.W.
Washington, D.C. 20235

Re: Cordell Bank Marine Sanctuary

Dear Ms. Allin.

The Environmental Forum of Marin would like to go on record as
supporting the creation of the proposed Cordell Bank National
@
arine Sanctuary. In reviewing the proposed alternative 1. See Generic Response A.
bundaries, we can support only the Alternative 0 1. In order
to
to protect the delicate food chain activities on the bank the
de5t possible area needs to be included within the sanctuary
boundaries. This also goes for the overlapping proposal for
0 fshore oil leasing. These are incompatible designations and 2. See Generic Response B.
[any'. activity related to exploration, drilling or mining must be
r.
restricted in the sanctuary.

We are excited to find an offshore proposal we can fully sup-
port. The future of our offshore marine life may well rest on
how quickly these delicate ecosystems receive complete sanctu-
ary status.

We do find the extremely short time for public comment rather
disturbing and hope a more expeditious system of notice can be
developed in the future.

Most S* erely,
ec .
X [email protected] 0--, , @TJ314197!,,@
Vir ia Souders-Mason
Pres dent
Iffn )A

FORT MASON CENTER
SAN FRANCISCO, CA ~94~123
(410~4744020 Edward Walsh. Jr.
~L~eg~.~1 ~C ... ~s~ol

BOARD OF DIRECTORS September 25, 1987
Cleveland Amory
~@~.~x~id~i~in~t ~C~l~,-...
Gretchen Wyler
v... C~i,--
Marian Probst Ms. Vicki Allin, Acting Chief
~S-~I~i~i~i~y
~P~"~s~c~i~l~ia Cohn Marine & Estuarine Management
~Dei Dona~l~a Division
Michael Kilian Office of Ocean & Coastal Resource
Judith Noy Management
Rhoda Pritzker National Ocean ~Survice~qlN~OAA
Lee Romney Washington, D.C. 20235
Frances Sca~ife
Trish Van ~De~vere Scott
Amory Winthrop Dear Ms. Al~lin,
Lewis Regenstein 1. See Generic Response A.
V- P-~d- We urge you to support the sanctuary status for
the Cordell Bank National Marine Sanctuary
Bill and La~vada Saxon (alternative #2; Boundary alternative #2)
Chuck and Cindy Trais~o 2. See Generic Response B.
T~r~u~x~, ~S-c-~r~, 'So' r~'e the ban on offshore oil and gas
~A~..p~l~.~6q4eti~qon nd development, be extended to the
L~i,a~4q=bo whole boundary of the sanctuary.
~,-.~1 C-~-~1.~1
Donna Gregory
It is so important to keep the possibility of an
oil leak completely away from the sanctuaries
FIELD AGENT, COORDINATORS marine life -- one mistake could destroy the
Cathy Sue Anun~sen. Oregon sanctuary for years.
Margaret Asproyerak~is. Illinois
Cynthia ~Bran~igan, Florida
George Campbell, Sanibel Island Thank you for your consideration.
Glenn Chase. Washington. D~.
Bill Curran, Massachusetts Sincerely,
Doris Dixon. Michigan
Caroline Gilbert. South Carolina
Gregory Gor~ney. Ohio
Virginia Handley, California
Cynthia Hatton, Mississippi
Joan Jen~n~Ch~. Florida
Milton Kaufmann, Maryland
Richard Kenly. New Jersey
Marlene Lakin. Toronto
Sid Rosenthal. Louisiana
Don~t Stark-R~ie~mer, Albany
Sherrie T~ipp~ie. Colorado
Paula Van Orden. Los Angeles
Paul Watson, Vancouver
Barbara Zell. Minnesota

200 WEST 5~7th STREET ~- NEW YORK. N.Y. 10019
Telephone: (212) 246~-2096 / ~(212) 246-2632

Go~8qk~qlen Gate Audubon So~c~6q*ty

~M~W A or TH~z N~A~T~a~o~x~q@ ~Au~m~m~oN S~oc~urr~@
S~m~v~m~c ~S~A~N ~F~k~A~Nc~moo Am ~P~q"~T~s or A~L~A~q@~A Am C~o~N~n~@ C~o~rrA COUNT ~2q7~q0929~q4

October 2, 1987

Mr. C. William Verity, Jr., Secretary of Commerce
Department of Commerce
Washington, D.C. 20230 C~M

~6qV~a~p I ~~T~Y
Dear Mr.

The Golden Gate Audubon Society urges you to cr~eate~a 1. See Generic Response A.
Cordell Banks National Marine Sanctuary. We, therefore, urge Ou
~qU~- ~- ~i~z
to adopt ~the preferred alternative (Alternative #2, Boundary
Alternative #2) in the DEIS now being evaluated.

We in the Golden Gate Chapter, National Audubon's second
largest chapter with over 6,000 members, are well acquainted with
the "Banks". Our members are constantly visiting it, by boat, of
course, because of its incredibly rich birdlife. we know it to be
one of the important natural resources off the West Coast. Please
give it the protection it deserves by making it a National Marine 2. See ~C~-eneric Response B.
Sanctuary and by banning offshore gas and oil exploration and
development over its entire boundary. Thank you for your
consideration.

Sincerely rs

Arthur Feinstein, President

AMERICANS ~COMM~Ir~ODT~O CONSERV~A~n~ON
15~50 Shattuck Avenue, Suite 2~04 ~- Berkeley, California 94709 ~- (415) 8~43~-2222

4AFEN?fACC
11 W E S T 0 F F I C E
FORT MASON - BLDG. E - SAN FRANCISCO - CALIF - 94123
( 4 1 5 ) 4 7 4 - 6 7 6 7 - T E L E X 3 4 0 2 7 5

October 7,

Ms. Vickie Allin
Marine Estuaries Management
Division
office of Ocean and Coastal Resource
Management
National Ocean Service/NOAA
Washington D.C. 20230

Dear Ms. Allin:

I am writing this letter support of the designation of Cordell
Bank as a National Marine Sanctuary. There is simply nothing quite
like this rich marine environment anywhere, it is irreplaceable.
Greenpeace supports boundary alternative #1 because Cordell Bank
contains a much needed buffer zone. oilspills and drilling muds 1. See Generic Response A.
from OCS operations are both capable of traveling great distances
and a buffer zone would ensure the bank's safety. Drilling muds
contains toxins such as heavy metals. Californians are well
aware of the problems associated with oil spills through the
Puerto Rican oil spill of 1984, and the recent sinking of the
Pac Barones.

We are deeply concerned that there are no provisions in the
present Sanctuary proposal to ban oil and gas leasing within the
sanctuary boundaries. It is frustrating to us that the sanctuary
program has not been given the same protections guaranteed to our
national parks and wilderness areas. Although Cordell Bank is not 2. See Generic Response B.
included in the present five year plan, there was interest by the
oil industry in the bank in 1978 and there is no reason to assume
that it wouldn't be proposed for the i,ext five year plan.
Gceeiip.ace bel-evez thzzt ta ban Cn oil and nas leasin,
1 .1 nho,ild
be the cornerstone of any sanctuary p-oposal.

We at Greenpeace are very enthusiastic of the marine Sanctuary
Program and hope that our suggestions are taken into
consideration the decision making process. Thank you.

Sincp@elyr
,-4 P4,--
Er1K1 Jo nson
Greenpeace
Fort Mason BIg. E
San Francisco, CA
94123 1%

8Z L7-,3 -

Q1kFfN?6ACC
If W E ST 0 F F I C. F
FORT MASON - BLDG. F - SAN FRANCISCO - CALIF - 94)Z3
( 4 1 5 )4 7 4 - 6 7 6 7-T E L E X3 4 02 7 5

My name is Erik Johnson and I'm here tonight representing
Greenpeace. Greenpeace is an international organization with
officesin 17 different countries and a membership of 200,000 in
California alone.

I have a brief statement prepared tonight regarding the proposal
to create the Cordell Bank National Marine Sanctuary.

we feel very strongly that NOAA adopt boundary alternative #1
which would provide the broadest area of protection. We feel that
itis absolutely necessary to include a ban on OCS oil and gas
leasing as part of the regulatory framework for the entire
National Marine Sanctuary from the beginning.

There are several reasons why both of these provisions are
necessary.

First there is simply nothing quite like Cordell Bank on the
entire coastline. it is a thriving marine environment. Shallow
waters allow a high degree of light penetration for
photosynthesis in algae and plants. In addition there is a high
nutrient concentration because of surface currents and upwelling.
This ecosystem supports an incrediblp diversity of marine life
including a number of endangered species. Humpbacked whales have
been feeding on krill there all summer long. Gray whales, blue
whales, finback whales, the brown pelican, and the short tailed
albatross also have been observed on Cordell Bank.

Boundary alternatives #2 and #3 are completely inadequate to
protect such an important resource. The larger of the two,
boundary alternative 02, contains no buffer zone that would
protect the bank from drilling muds and oilspills. Plumes of
toxic drilling muds are capable of traveling miles from their
sources. Drilling muds contain heavy metals such as barite, zinc,
chronium, and in some cases mercury. oilspilis can also travel
great distances. oil from the Puerto Rican tanker spill stretched
for 140 miles. The fuel oil from recent sinking of the Pac
Barones stretched for twenty miles at one point.

We insist that there be a ban on oil and gas leasing on Cordell 3. The $50,000 maximum penalty is per day. Therefore an Offence that occurs
Bank because although there are no provisions for leasing there within the Sarctuary is liable for ccupensation at the established penalty
in the present five year plan that is no guarantee that it will urrtil the offence is mitigated or no lorger poses a threat to the Sanctuary.
not be included in the next round. A number of nominations were
received by the oil industry in 1978. A full ban on all OCS oil 4. See Generic Response D.
and gas drilling should be the cornerstone of any marine sanctuary
proposal.
[Tinally, we believe that the $50,000 maximum penalty for any
1
olations of the Sanctuary regulations is completely inadequate.
9 one could put monetary value on the loss that would occur if a
major spill occurred on Cordell Bank, we feel it would be a great
deal higher and urge that the penalties be raised significantly.
lWe also urge that the budget for managing the sanctuary be raised

significantly and that an oil spill recovery team be stationed in Bodega Bay rather
than San Francisco.

GREENPEACE

LEAGUE OF WOMEN VOTERS OF MARIN COUNTY - 412 D SI,eel - San Rafael, California 94901 . (415) 459 0292

October 10, 1987

Ms. Vickie Allin, Acting Chief
Marine and Estuaries Management Division
Office of Ocean and Coastal Resource Management
National Ocean Service/NOAA
1825 Connecticut Avenue, N.W.
Washington, D.C. 20235

Re: Cordell Bank National Marine Sanctuary.

Dear Ms. Allin,

We are a member of the League of Women Voters Northern California
Coalition. A long letter has be sent to you regarding our support
of the Cordell Bank Marine Sanctuary by our Chairperson Kathleen
Gordon. As an ij1dividual League we wanted to stress two points
that were discussed at great lengths in the above mentioned let-
ter.

We first want to congratulate,NOAA on the designation of Cordell
Bank as a National Marine Sanctuary. Such ecologically productivE
j1reas for marine life are national treasures that must not be al-
lowed to degrade. That is why we find the overlapping of the pro-
posed boundary #1, which we deem the best alternative, and the
oposed offshore oil leasing area to be in conflict. Within the 1- See Generic Response A.
Marine Sanctuary Boundary Should be a "No Activity" zone for hy-
drocarbon exploration and development to protect no only Cordell
Bank but also The Gulf of the Farallones Marine Sanctuary.
2. See Generic Response B.
Our second concern is with the extremely short time between publi<
notice and the close of time for written comment. Natural re-
source issues are important to the California public and we wish
be remain involved in the decision making process. We would ap-
preciate being placed on public notice mailing lists for future
information regarding Cordell Bank.
Sincerely, @- @03416V
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Ma
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Roberta Keiler
LO
President It
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LEAGUE OF WOMEN VOTERS
CALIFORNIA COALITION
P.O. Box 196, The Sea Ranch, CA. 95497

10 October 1937

Ms. Vickie Allin, Acting Chief
Marine and Estuarine Management Division
Office of Ocean and Coastal Resource
National Ocean Service/N0AA
1825 Connecticut Avenue, N.W.
Washington, D.C. 20235
Re: Draft Environmental Impact Statement/ Management Plan -
Cordell Bank National Marine Sanctuary

The League of Women Voters Northern California Coalition is made up of
the Leagues of the Bay Area, Marin County, Sonoma County, Napa County,
Ukiah, Mendocino County and Humboldt County. The Coalition was organ-
ized to gather information, study and respond to issues related to
offshore oil exploration, drilling, production and transportation. We
noted in connection with Department of Interior's Proposed 5-Year Outer
Continental Shelf (OCS) Oil & Gas Leasing Program for 1987-1991 that the
BIS for the Cordell Bank National Marine Sanctuary was in process. it is,
therefore gratifying to be able to respond to your Division's proposed
D

DEIS/Management Plan.

The Coalition congratulates NOAA on its proposal to designate the Cordell
Bank as a National Marine Sanctuary. We agree with your selection of
the Sanctuary designation as the preferred alternative to the Status Quo
alternative. We are very supportive, as are state and the national Leagues,
of efforts toward the wise use of natural resources and the preservation of
the physical, chemical and biological integrity of the ecosystem. We find
this especially critical in the case of unique or fragile areas, such as
Cordell Bank.

We urge the selection of Boundary Alternative No. 1 since it will provide
significantly better protection for the immediate fishing grounds and the 1. See Generic Responce A.
surrounding area. Vie believe that the protective measures should be put
into effect as soon as possible. In view of the values of the benthic
resources of Cordell Bank to scientific research and fisheries, the
protective measures should include prohibiting harmful discharges from
vessels, prohibiting removal or damage of banthic resources, establishing
a "No activity" zone for hydrocarbon exploration and development, and
establishing monitoring programs. Our Coalition does not find it prudent
to Wait, as the "No Immediate Regulation" alternative for hydrocaroon 2. See Generic Response B.
Development Activities Proposes, until after a Lease Program is in place
to begin to consider whether _________oil development operations are or
are not appropriate. We would hope to see the "Immediate Regulation"
alternative adopted to provide the crucial protection for Cordell Bank and

Allin, NOAA - Cordell Bank NMS 10/10/87

The nearby Point Reyes/Farallon Islands National Marine Sanctuary based upon
the risks described in the Environmental Consequences of the DEIS.

We appreciate the additional time for written comment, since the public
notice in the local areas for hearings was Friday to the following Tuesday,
allowing very little time for interested public to secure and review copies of
the DEIS. We do urge you to continue to involve the public in the decision
making process for important issues such as the protection of the Cordell
Bank.

Sincerely,

Kathleen Gordon, Chairperson

cc: Mr. Edward Wilcynski, Acting Chief
Ecology and Conservation Division
U.S. Department of Commerce, Room 6814
Washington, D.C. 20230

Mr. C. William Verity, Jr., Secretary Designe
U.S. Department of Commerce
Washington, D.C. 20230

Marin

Community
College
Kentfield, CA 94904
(415)457-8811

September 18, 1987

Ms Vickie Allin, Acting Chief
Marine and Estuarine Division Manager
Of fi ce of Ocean and Coastal Resource Manager
National Ocean Service/NOAA
1825 Connecticut Avenue, N.W.
Washington, D.C. 20235

Dear Ms. Allin:

This letter is a highly supportive vote for the Draft Environ-
mental Impact Statement/Management Plan for the Cordell Bank
National Marine Sanctuary.

I have spent some 33 years observing the marine ecology of the
waters in and around the Cordell Bank and have been an active
diver on the Bank itself. My comments below reflect years of
expertise in these waters from the Cordell Bank to the Marin -
San Francisco Bay Area - involving about 24 publications of the
biota of these marine waters.

Statements and Recommendations

1. The value of the CBNMS is that it truly is a unique marine
ecosystem and is certainly worthy of Sanctuary status.

2. It is yet unknown how the ecosystem of the Bank affects the
entire Gulf of the Farallones - San Francisco Bay Estuary
System. The Bank appears to be a biological sentinel on the
edge of this important marine water system, and such poten-
tial is worthy of sanctuary protection and future research.

3. The hydrocoral, Allopora californica, is a large population,
and must be pre served from potential destructive mechanical 1. Comment accepted. All california
forces, such as sea anchors and gill net operations. I agree hydrocoral is riot a federally or state
that oil spills of past magnitudes have not posed a threat to massive density of the coral on Cordell
this biota, but the future.potential from a nearby oil plat- special attention and protection that will
form spill in the Bodega Basin might be a distance concern. area as a marine Sanctuary. Also gee
The species is not rare, as stated on page 5. it is endemic
to deep-cold watErs and the species can be abundantly found
from Northern California to the Isla San Martin area of the
Baja-Pacific. The massive density of the Allopora on Cordell
Bank is most unique and requires protection.

COLLEGE OF MARIN CAMPUS Kentfield/457-8811 Indian Valley College Campus_________

Ms. Vickie Allin, Acting Chief
Marine and Estuarine Division Manager
Office of ocean and Coastal Resource Manager
September 17, 1987
Page 2

4. Iufavor the Proposed Boundary No. 2 as the most practical and 2. See Generic Response A.
s fficient for protection.

5. 1 also favor Management Alternative No. 2 where CBNMS is fused
to PRNMS. Such management should expand the advertisement of 3. No Response Necessary.
the Bank through educational diorama and brochures. Moreover,
such historical releases should always mention the work of
Dr. Robert W. Schmieder. This DEIS would not be possible with-
out his collective years of data.
I recommend an addition to management - to form a Scientific 4. NOM supports this idea and hopes to have the advise of the scientific
Advisory Committee to assist the actions of the future CBNMS_ camunity inoorpc)rated into the management structure of the Sanctuary.
PRNMS administrators.

Thank you for this reviewer opportunity. Please keep me on
your mailing list of events.

Sincerely,
cp
Gordon L. Chan, Ph.D.
Biology Department

GLC/cfp
cc: Dr. E. Wilczynski
Dr. R. W. Schmieder

Mann Audubon Society Box~8q5~4q9~4q9 M~2qd~qf V~4~q1~q4~q1~qp Ca~qf~4qorn~ta~,94942~-0~8q5~4q9~0q3
October 9, 1~987

Vickie Allin, Acting Chief
Marino and ~6~stru~a~in~o Management Division
Office of Ocean and Coastal R~e~ar~o7u~c~o Management
National Ocean ~B~erv~ic~e~q/~M~O~A~A
1~025 Connecticut Avenue. 0.~1~1.
Washington, D.C. 20235

Dear ~M~e All~en~t

This in to express support establishment of the Cordell Bank
National Marine Sanctuary. Cordell Bank is an extremely rich and
productive marine ecological com~oun~ity supporting substantial
populations of fish, crustaceans. marine mammals and seabirds.
Further, Alternative #1 boundary is the only reasonable and safe ~1. See Generic Res~p~or~se A.
b~aound~ary to provide the critical protections needed for this
unique habitat. This fragile habitat r~o~s~o~u~c~o is vulnerable from
numerous human-related activities.

We appreciate your full consideration of our recommendations.

Sinc~6qr~e~'~.~1~8qh~y~,

rbar~a ~B~e 'Chair
Cons~erv on Committee
~v
on C~,

OCT ~q198~q7
~M

A Chapter of National Audubon Society

MARIN CONSERVATION LEAGUE
A non profit corporation ~l~o~l~i~n~ded in ~f~g~.~@~4

13~3~0 Lincoln Avenue, San ~R~a~f~a~e~i~, CA 94901
Office ~(~e~~tep~t~i~one: ~.~4~56~-1912

~4q1~2q0~(~q)~q1~q4~4q5
A~~4~6~4 ~W~@~d
Kill~~l~i~a~r~n~i~i~a~p~w~. Address change: 3~S Mitchell ~aou~i~evar~d, suite 11
Sarno.~] ~T~0~1~0~1 Poll, San Rafael, CA 94903 ~-
Buono~, ~"~g~o~,,~n~l~g~e~n~t Islam
~~~k~o~.~o~n ~1~3~.~a~c~t~, Office telephone: 472-~5~1~4q3
Makes ~0 y ~b~eacr~i
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~~k~h~a~ld- ~B~a~y ~S~.~0~qm~i~t~'~l,
C~.~f~.
Modern T~i~f~t~%~n~d~l ~4~qM
~~t~'~"~b~e~l~l~y ~l~i~o~m~a~w~@
~~o~l~t~v, ~1~1~4~J~@~h ~.
~~o~e~'d~l ~14~8~3~h
~~m N~@~t~t,~`~M~q~.
F~~i~e~n~c~i~f~. ~o~t~q-~p~a~l~. Mr. C. William Verity, Jr., Secretary ~Des~i~g~ne
M~a~l~q@~n~'. A~(~qM~.~R~..~1 Land. United States Department of Commerce
Mal ~@ ~4 ~C~W~'~V ~F~.- w~a~s~h~i~n~gto~r~k, D.C. 20230
~ .. ~t~o~) ~P~'~w~e~c~v~.~n
(~~0~1~0~" Gate ~N~a~l~i~-~a~(
R-~"~(~i~@ 0-~a
C~i~f~th~o~'~. ~O~'~l ~D~"~l~l~i~n~g Dear Mr. Verity,
~~.
~a~k. Planning ~1-~6~@
WOO and ~&~o~n~i~c It~q-
~ ~f a., The M~ar~i~n Conservation League urges your support in establishing
P~o~w~sk~i~i~i~n~t the Cordell Bank National Marine Sanctuary.
now moo",
~~qW~U~M~.~0 Moo This is a highly productive ~"island" under the sea, supporting an
Kona ~U~N~q~ important fishery, and biologically unique populations of ~be~r~ithic ~-~,~q4o Response Necessa~qxy~.
Politic ~E~w~i~e~h~o~n ~c~o~o~p~t~i~s~n~o~l~o~o
~~s~i~l~t~i~f~a~n~n~* ~w~f~t~o~n organisms, Because the area is located so close to islands
~~"~I~d ~.~1 ~a~t~n~i~t~t~o~'~s supporting breeding colonies of marine mammals and sea birds and
Pete( ~f~i~e~m because of the uniqueness of its own flora and fau~n~a~z it is a
~~qw ~s~w~e~r~t~in~e~i~.~, major and significant area to protect.
sandy ~a~l~.~.~'~m
Joan E~l~q-~w~n~a~@~k~o~i~t
We have long supported inclusion Of the Cordell bank in the
~6~.~1~1
~c~u-~i~-~4~6 Marine Sanctuary Program. We hope to see it become a reality.

~~)w~i~a D~o~r~ican
Victoria ~5~1~A~.. S~i cer y

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~~o~p~, ~H~.~0~0~, President
Susan ~l~"~S
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A~U~n ~J~o~n~n~s~f~o~. cc: Defenders of Wildlife
~Ow~. ~L~i~n~d~l-
Al.,, ~I~t~ha~l~e Center
P~o~n~n~y ~M~a~l~l~f~l~a~rd
Willa Marlon
Bill ~f~f~t~l~i~(~6
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Chip ~W~l~a~t
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To Preserve and protect the natural assets of M~a~T~i~n County for all pe~o~p~t~e

)ANN
NaturalResomes
Defense Council

90 Nm Montgo e,y
San Francisco, CA 94105
415 777-0220

October 9, 1987 VIA FEDERAL EXPRESS

RE: Comments on Cordell Bank National Marine Sanctuary
-- Draft Environmental Impact Statement/Management
Plan

Dear Ms. Allin:

Enclosed are the comments of the Natural Resources Defense
Council, Inc., on the draft environmental impact
statementImanagement plan on the proposed Cordell Bank
National Marine Sanctuary.

Overall, NRDC strongly supports the designation of Cordell
Bank as a marine sanctuary. However, as set forth in our
comments, we believe the proposal is seriously flawed and
fails to provide adequate protection for the sanctuary's
outstanding resources. Specifically we have addressed our
comments to the areas of boundary size, regulation of
hydrocarbon development, and sanctuary management.

We recognize the considerable work your office has done on
this project since the sanctuary was proposed in 1981. We
commend your efforts and hope that you will seriously
consider our comments in the preparation of the final EIS
and plan.

Sincerely,

-,e 1416
Bruce Goldstein ft
California Coastal Project

6-Z 9Z

Neiv York Offia Washington Office: Nm EngLand Office T(,xic Substances
122 East 42nd Stred L350 Nm Yolk Aw, N. W 850 Boston Post Road Infomuntuni Line:
New York, Nhu York 10168 Washington, DC 20005 Sudbury, MA 01776 USA: 1-800 648-NRDC
1114444044 202 783-7800 61744.3-63(X) NYS: 212 687-6862

COMMENTS OF THE

NATURAL RESOURCES DEFENSE COUNCIL

ON THE

DRAFT ENVIRONMENTAL IMPACT STATEMENT/MANAGEMENT PLAN

ON THE

CORDELL BANK NATIONAL MARINE SANCTUARY

October 9, 1987

Prepared by:

Bruce Goldstein
Johanna Wald

California Coastal
Project

The Natural Resources Defense Council, Inc. (NRDC) is a non-

profit environmental membership organization with over 65,000

members and offices in San Francisco, New York, and Washington,

D.C. NRDC is pleased to submit the following comments on the

proposed Cordell Bank National Marine Sanctuary. In them we

specifically address the May, 1987 draft environmental impact

statement/management plan (DEIS) prepared by the Marine Estuarine

Management Division of the National Oceanic and Atmospheric
Administration.1

1. The Marine Sanctuary Designation

NRDC strongly supports the designation of this uniquely rich

area as a marine sanctuary. A rare combination of favorable

ocean currents, nutrient upwollings, and sunlight penetration has

created an incredibly diverse ecological community. This

vigorous community is concentrated on the "undersea island" of

Cordell Bank and supports an entire food chain from benthic

organisms to large birds, fish and mammals. Life found in the

area includes varieties previously unknown in these waters as

well as at least four endangered species -- the humpback whale,

the blue whale, the Brown pelican, and the short-tailed

albatross.

The National Marine Sanctuary designation is needed so that

preservation of this special Cordell Bank resource is permanently

insured. The proposed sanctuary plan is intended to achieve this

1 unless otherwise indicated, page references are to the DEIS.

goal. The DEIS states that long term protection of these

resources is the highest priority of the plan. (pp. xi, 39).

Under the proposed sanctuary designation and plan, this
protection is to be achieved by prohibiting vessel discharges and

removal of benthic organisms (except for research purposes).

While these are important steps, the sanctuary as currently

conceived in the "preferred alternative" is inadequate in its

scope and defective in its proposed implementation. Without

adoption of the changes recommended below, NRDC fears that the

goal of resource preservation for Cordell Bank will not be

accomplished.

11. Sanctuary poundaries

NRDC supports the adoption of Boundary Alternative 1 over

the preferred alternative (Boundary Alternative 2). Alternative
1 received the most support in feedback previously solicited by 1. See Generic Response A.
NOAA (p.65) and, based on testimony presented at the September

California hearings, continues to be the "preferred alternative."

Boundary Alternative 1, approximately 300 square nautical miles

larger than Alternative 2, would create the type of buffer zone

that genuinely protects the ecological community of Cordell Bank.

We disagree that the preferred alternative is "tailored to

specific resources" in accordance with the Sanctuary Program

goals. (p.65) Ocean currents rich with nutrients extend beyond

the immediate Bank area to support fish, seabirds, and mammals.

(Testimony of Robert Schmieder, Expedition Leader, Cordell Bank

Expeditions, DEIS Hearing, 9/26/87, Fort Mason, California.)

These diverse life forms, which sometimes feed and congregate

beyond the Boundary 2 area, are an integral part of the Cordell

Bank ecosystem and should be afforded maximum protection.

Boundary Alternative I serves to better protect these citizens of

the Bank.

The need for a meaningful buffer zone is especially

critical when considered in light of possible hydrocarbon

pollution. The Cordell Bank area is of continued interest to the

oil industry (See III. Hydrocarbon Regulations). Should oil

development take place, sanctuary life will be at great risk.

Drilling discharges and mud drifts contain heavy metals and

chemicals that are particularly toxic to the benthic biota. (p.

81-82) Drilling pollutant plumes can travel long distances,

emphasizing the need for the larger Boundary 1 alternative. The

DEIS' conclusory statements that Cordell Bank would be protected

from the discharges because of strong currents and a drilling

prohibition within the 50 fathom contour (p. 82) are neither

supported nor credible.

The need for a larger oil free boundary zone is further

supported by the DEIS' finding that, if "oil development were to

take place in the area of Cordell Bank, spills from blowouts and

platform accidents are likely to occur, although the volume

spilled would probably be minor." (p. 85) While we appreciate

the optimism that any spill "would probably be minor", the fact

is that the most recent oil spill off the California coast was

major and involved the loss of over 56,000 gallons from the Pac

Baroness. See Los Angeles Times, September 29, 1987, p. 3.) So

too was the 5,000 barrel Puerto Rican spill. Under these

circumstances, we think it best not to risk the biological

integrity of the sanctuary on such speculation.

As the DEIS points out, oil spills can present a

particularly dangerous threat because of the creation of a

subsurface plume of oil droplets with high concentrations of
alkyl benzene and naphthalene which are acutely toxic to marine

organisms. (p. 83) The interior Department has estimated that

offshore containment and cleanup operations average only 5% to

15% recovery of spilled oil. (Department of the Interior, Draft

Environmental Impact Statement for Lease Sale 97 at IV-A-15.)

The California Coastal Commission has found that practical use of

mechanical spill clean-up equipment is limited to 6-foot seas --

a level frequently exceeded in the Cordell Bank area. Both the

Pac Baroness and Puerto Rican spills reveal that the oil industry

and the federal government lack the ability to respond

effectively to oil spills that might occur in this area.

Finally, adoption of Boundary Alternative I would create a

contiguous border with the Gulf of the Farallones Marine

Sanctuary. This would provide management and surveillance

benefits consistent with the DEIS' emphasis on coordination with

the FaralloneB Sanctuary administration. It would also help

avoid the potential problem of oil development or other uses of

the "gap" for purposes antithetical to that of a marine

sanctuary.

III. Hydrocarbon Regulations

It is difficult to understand the meaning of a "marine

sanctuary" designation without a prohibition on hydrocarbon

development. Such a prohibition has been incorporated in the
designation of all other sanctuaries in the national program. 2. See Generic Response B.
NRDC strongly supports the imnosition of a full ban on oil and

gas drilling activities within the entire Cordell Bank Sanctuarv

area. This ban should be in effect from the first day of

official sanctuary status.

The Department's rationale for not including regulations on

hydrocarbon development at this time is that Cordell Bank has

been excluded from the current Five-Year OCS oil and Gas Leasing

Program. (p.73) This exclusion provides little reassurance that

oil development will not eventually take place.

The oil industry urged the Department of the Interior to

include tracts within the proposed Cordell Bank Marine Sanctuary

in Lease Sale 53 when the tract selection process was conducted

in 1978. (p. 33) An agreement to place the entire Bodega Bay

Basin (including Cordell Bank) Off-liMitB to offshore drilling

until the year 2000 was reneged upon by Interior Secretary Hodel.

Instead, what we now have is the deferral of only the central

core area of the Bank (within the 50 fathom contour line) only

until 1992 when the current Five-Year OCS Leasing Program

expires.

There are several serious problems with this approach.

Given the policy reversals of the Department of the Interior, and

oil industry interest in this region, there is no guarantee that

the sanctuary will be secure from oil development in the next

Five Year Program. This reinforces the need to promulagate

regulations now, before imminent development or political

pressure makes permanent protection of the sanctuary more

difficult.

if oil and gas development were permitted within the

proposed sanctuary in the future, the DEIS only contemplates

regulations that would prohibit oil and gas exploration within a

50 fathom "no activity" zone. Development within an area of one

nautical mile beyond the "no activity zone" might then be

"monitored". The tentative nature of the monitoring is indicated

in the DEIS: "If (oil development] does occur NOAA's Marine and

Estuarine Management Division will investigate, in coordination

with the Department of the Interior, the necessity of instituting

a monitoring program." (p.73) (emphasis supplied).

The proposed management plan currently provides no

additional staff and budgets only $65,000 per year for sanctuary

protection and research. (p. 64) Without a significant

commitment of additional resources, monitoring, if it occurs at

all, will provide little meaningful protection to sanctuary life.

The fact that the current OCS leasing deferral and the future

contemplated sanctuary regulations only include an oil

development ban within the 50 fathom contour line is of acute

concern. As explained above (II. Sanctuary Boundar ), the

environmental impacts of oil drilling extend beyond the immediate

drill site. Protection within only the 50 fathom zone threatens

the central core of the sanctuary. It allows oil development to

practically hug "the island" segment.

The oil industry is not hesitant about drilling near

environmentally sensitive areas. The placement of oil platforms

at the edge of sanctuary boundaries has already occured at the

Channel Islands Marine Sanctuary. It is conceivable that in the

course of oil development, platforms would be anchored to Cordell

Bank "island" ledges, killing plant and benthic organisms that

compete for space in this densly crowded area. Even if this did

not occur, drilling within such close range of the sanctuary core

would present a clear danger to the ecological balance and health

of the Bank.

As stated above, Cordell Bank would be the only marine

sanctuary without full protection from hydrocarbon development if

the preferred alternative of the DEIS were adopted. KRDC firmly

believes that unless a ban on all hydrocarbon activity within the

entire boundary zone is included in sanctuary status, the

protective intent of the Marine Protection, Research, and

Sanctuaries Act will be violated. We strongly urge incorporation

of such a ban in the final environmental impact statement and

plan.

IV. Management Plan - Enforcement and Safety

The management plan puts great emphasis on consolidation and

coordination of sanctuary administration with existing agencies.

While NRDC supports the general thrust of the plan, we are
3. See Generic Response G.
concerned that a lack of resources and inadequate monitoring and

enforcement efforts Will severely compromise the protection of
Lthe sanctuary area. The plan essentially places all significant
responsibility for sanctuary protection from vessel discharges,

gill netting, and oil and gas development on the Coast Guard and

the California Department of Fish and Game (CDF&G).

Both of these agencies have significant responsibilities

beyond guardian of the sanctuary area. CDF&G in particular has

struggled with recent budget cutbacks to carry out their

extensive statutory responsibilities. The Coast Guard, in

addition to its proposed sanctuary duties, is responsible for

vessel traffic, boater safety, search and rescue operations, and

most recently a focus on illegal drug traffic interdiction.

The DEIS makes no mention of how these agencies will be able

to absorb their added sanctuary duties into current workloads. No

estimates appear as to how much time either organization will be

able to devote to sanctuary surveillance. The DEIS refers to an

"emphasis on protection ... rather than enforcement." (p.85)

Without specific agency commitments and a detailed framework of

how resource protection will actually be implemented, the promise

of protection is an empty one.

The plan also assumes that the staff functions of the

Cordell Bank Sanctuary can simply be absorbed by the current

Farallones Sanctuary staff. While consolidation should allow for

some staff and administrative savings, it is not clear that the

research, interpretation, and protection goals of the Cordell

Bank Sanctuary can be fulfilled by existing staff.

NRDC is particularly concerned about peak periods between
June and October when visitors to the center and to the Sanctuary
are highest. At the very least, additional staff who will focus 4. See Generic Response H.
on the specific needs of Cordell Bank should be added during peak

periods.

Finally, with the memory of the Puerto Rican oil spill and

more recently the collision of the Pac Baroness off Santa

Barbara, it is important to do everything possible to improve

ship safety around the sanctuary area. This might take the form

of special bouys, communication systems, or redirection of vessel

traffic. Adequate prevention actions are particularly important

given the painfully obvious limits of existing Oil spill clean-up

technology. Specific proposals to better safeguard shipping in

the area should be included as part of the final environmental

impact statement.

V. conclusion

NRDC strongly supports the creation of the Cordell Bank

National Marine Sanctuary. Cordell Bank is unique in the

diversity and density of its marine life and is a rare and

valuable national resource deserving federal protection.

However, we are concerned that the "preferred alternatives"

proposal severely compromises the biological integrity of the

,sanctuary.

Specifically, NRDC supports the inclusion of a meaningful

buffer zone that serves to protect the delicate "underwater

island." The area beyond the "island" also contains marine life

that is a vital part of the sanctuary ecology. Protection of

.this bio-region will be best achieved through adoption of

Boundary Alternative 1.

Further, a marine sanctuary plan that does not ban oil and

gas exploration and development within the entire sanctuary zone

is self-defeating. The inherent risks of such activities are too

great. The failure of the proposed plan to genuinely protect the

sanctuary zone from hydrocarbon discharges and spills violates

the intent of the Marine Research, Protection, and Sanctuaries

Act.

KRDC is also concerned that the management plan does not

adequately provide for sanctuary monitoring and enforcement

activities. It appears that, without detailed operational plans

which indicate how other agencies will effectively assume

sanctuary responsibilities, more staff and resources are needed.

The need for additional staff support is particularly critical

during peak periods. Finally, effective measures to prevent

shipping and especially tanker accidents in the greater Cordell

Bank area must be undertaken now.

The final environmental impact statement should insure that

sanctuary designation will preserve the uniqueness of Cordell

Bank in perpetuity. Incorpoaration of the recommendations set

forth above into the final plan will help acomplish that shared

goal.

-W
Box 95q&3

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[email protected]

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SAN FRANCISCO BAY CHAPTER
OCEANIC SOCIETY
SLOG. E. FORT MASON SAN FRANCISCO, CA 94123 - PHONE J415) 441-5970

October 8, 1987

Ms. Vickie Allin, Acting Chief
Marine and Estuarine Management Division, OCRM
National ocean Service/NOAA
1825 Connecticut Avenue, N.W.
Washington, DC 20235

Dear Ms. Allin:

The Oceanic Society, San Francisco Bay Chapter, supports
the des ignation of Cordell Bank as a National Marine Sanctuary.
Cordell Bank is an extraordinary, isolated and fragile resource
that must be protected. It is distinguished by its unusual
combi@ation of subtidal and intertidal species, the presence of
organisms found nowhere else at these latitudes or at these
depths, its dense populations of rockfish, and by the discovery
of a number of previously unknown benthic species (sponges).
We support the proposed management regulations restricting 1. See Generic Response A.
vessel discharges and the collection or disturbance of benthic life
in sanctuary waters. We are convinced, however, that the
preferred Boundary Alternative #2 is too small and we support
the designation of Boundary Alternative #1. 'Further, we believe
-nere should be no oil development operations within this
boundary from the outset in order to be consistent with the
National Marine Sanctuary program's stated conservation goals.

The preferred alternative notes that the Cordell Bank area has
been deferred from leasing for the next five-year OCS program,
but goes on to state that, if in the future, oil and gas
exploration and development is allowed 11 ... within the boundaries
of the Sanctuary ... a sanctuary regulation may" - or may not - "be
promulgated to prohibit such operations within a "no activity-
zone encompassed by the fifty fathom contour around the Bank." 2. see Generic Response B.
The preferred alternative also promises that such activity within
a nautical mile of the fifty fathom isobath will be "monitored"
by sanctuary staff should it seem to pose a hazard to the
ecosystem of the Bank. There is no mention at all of any
authority given to sanctuary staff to limit or prohibit drilling
if their monitoring convinces them that there is indeed a hazard.
This is inadequate protection, particularly if, in the end, a "no
activity" zone is not created, and an oil rig is placed directly

atop the Bank itself, with all the attendant impacts on the life
around and below it.

The unusual depth to which this ecosystem extends (some 35
fathoms), the density and variety of its components - algae,
sponges, rockfish, seabirds and marine mammals - are all founded
on high photosynthetic activity, especially in the algae growing
in the dim light of the lower reaches of the Bank. This primary
productivity is, in turn, absolutely dependent on the
extraordinary clarity of the water column; visibility is normally
65 feet or more, sometimes more than 100 feet. One of the most
distinctive features of Cordell Bank is the presence, in
abundance, of the rare purple hydrocoral Allopora californica.
found only in waters of pristine clarity. It supports an entire
community of organisms that depend on it and live nowhere else;
the polychaete worm Polydora alloporis and the small barnacle
Armatobalanus nefrens, which live completely encased in the
hydrocoral's branches, and the pink snail Pedicularia californica
that lives among the branches. It also supports many species of
algae. oil drilling activities could adversely affect these
hydrocorals and their associated organisms if a platform were
located even several miles away, discharging many thousands of
tons of drilling muds and cuttings into the water.

Over a production platform's many years of operation,
increased turbidity alone would be a serious threat to life on
the Bank. Photosynthesis would be impaired, particularly at lower
depths; filter-feeding organisms would be hampered by the water's
increased particulate load, and the consequences could spread
upward through the food chain. Likewise, even if there were no
major oil spill, the many small scale leaks of waste and
hydrocarbon spillage which are inevitable (even according to the
draft EIS) in an operation as complex as an oil platform, could
easily cause toxic effects; for adult planktonic animals, lethal
doses of soluble aromatics can be as low as .1 parts per million,
and larval stages are usually 10 to 100 times more sensitive. As
the Draft EIS itself states: "Chronic small spills may pose a
greater hazard than isolated large spills".

The proposed possible restriction of oil and gas activity
to the area outside the fifty fathom line would be of limited
significance, as the effects of toxic and particulate pollution
dispersing from nearby platforms would be cumulative over years.
Moreover, it must be noted that the fifty fathom line is usually
less than a mile distant from the shallower areas supporting high
concentrations of benthic life (especially on the steep western
slope that drops to the abyssal plain). Of course, a major spill
would be a disaster if it crossed the Bank; the feathers of
seabirds and the fur of seals and sea lions that feed there would
be fouled, and the ingested toxins would be particularly harmful.

Clearly, allowing oil and gas exploration and development
within Cordell Bank National Marine Sanctuary would not be

R1 DG F FORT MARnN SAN FRANCIS(() CA 11411-1 1'- ".... ...

consistent with conserving the resource.

Just as clearly, Boundary #2 proposed in the preferred
alternative, 3 miles out from the fifty fathom isobath, would be
inadequate protection for Cordell Bank's water purity even if
there were a ban on oil and gas activity within the borders.
Increased particulate load and toxic hydrocarbons could still
cross the Bank, particularly if their source were located
upcurrent of either of the two major seasonal currents. In the
event of a major oil spill or blowout from a well just beyond the
boundary there would be only a few miles for the slick to break
up, if wind and current sent it across the Bank. Given the
practical limits of known spill control and cleanup methods, all
the "co-ordination between government agencies" promised in the
management plan would of little help at that point. The oil slick
resulting from the breakup of the tanker Puerto Rican in the
Gulf of the Farallones in 1984 is a case in point. Shifting winds
and currents caught planners by surprise; the oil defied the
containment booms and clogged the skimmers. In the end only
1,460 barrels of 48,000 were cleaned up.

We strongly urge the adoption of Boundary Alternative #I,
running southwest from Bodega Head to the 1,000 fathom line, then
south to the Point Reyes/Farallones Islands Sanctuary border, as
a sufficient safeguard for the Cordell Bank ecosystem. In
addition to the reasons given above, we believe that this
boundary would protect the area between Point Reyes and Cordell
Bank. This is a vital area of transit, since, to quote the DEIS,
11 ... many of the marine mammals and seabirds that visit Cordell
Bank to feed in its waters are also dependent on habitats in the
Point Reyes National Marine Sanctuary".

Boundary Alternative #1 is needed to protect the continuous
corridor from Bodega Bay to the Farallones used by the large
whales. In the summer, in particular, there is frequent migration
of whales between Cordell Bank and the Farallones for feeding
purposes. During periods of migration, the large whales migrate
in depths of 100 to 1000 fathoms. The gray whales use a corridor
closer to shore. Failure to include these waters in the boundary
designation would leave an unprotected gap.

The entire region - the coast and islands already included
in a sanctuary, and the underwater bank now being considered for
protection - must be studied, and protected, as a whole.
Boundary #1 would rationalize management by creating a single,
unbroken unit out of the two adjoining sanctuaries, eliminating
the intruding arm of unprotected, unregulated sea - which is
largely included in the area of the proposed OCS Lease Sale #91 -
from which any pollution or disruption of sensitive wildlife by
unrestricted activity could impact the protected waters that
surround it on three sides.

Thank you for considering our concerns. We hope that if and

when the proposed sanctuary comes into being, the mechanisms for
resource protection and the program of management strategies will
be consistent with the sanctuary's stated goals.

Yours sincerely,

Joan Patton
Conservation Director

PACIFIC COAST FEDERATION OF FiSIIERMENS
ASSMIATIONS, INCORPORATED

Reply to:
LI P.O. Box 1626 F1 P.O. Box 1896
Sausalito, CA 94966 Sacram.m., CA 95809
(415) 332@5080 1916) 448-8805

9 October 1987

Ms. Vickie Allin, Acting Chief
Marine & Estuarine Management Division
Office of Ocean & Coastal Resource management
NATIONAL OCEAN SERVICE/NOAA
1825 Connecticut Avenue, N.W.
Washington, D.C. 20235

RE: Draft Environmental Impact Statement/Management Plan
CORDELL BANK NATIONAL MARINE SANCTUARY

Dear Ms. Allin:

The Pacific Coast Federation of Fishermen's Associations
represents 24 commercial fishermen's organizations along the
U.S. west coast. Many of the fishermen belonging to PCFFA
member orqaniztions will conduct fishing operations within
the course of a fishinq season(s). PCFFA has reviewed the
above entitled document and has the following comments/
recommendations:

1. The Cordell Bank supports a rich and vital commercial
and recreational fishing industry. This fishery has and is
managed by a combination of state (i.e., California Department 1. Ccinnent Accepted. See Generic Response I.
of Fish & Game) and federal (i.e., Pacific Fishery Management
Council, National Marine Fisheries Service) authorities. These
agencies have expertise in fisheries management and, it is our
recommendation in the event of the establishment of a federal
marine sanctuary for the Cordell Bank, should retain management
and regulatory control over the commercial and, recreational
fisheries for this area (as is recommended in the DEIS).

2. Due to the uniaueness of the Cordell Bank and its
rich biological productivity, adequate boundaries must be 2. See Generic Response A.
established to provide it the maiximum protection possible.
I'We recommend therefore that Proposed Boundary #1 be established.
3. Aqain, because of the uniqueness of this area and 3. See Generic Response B.
its rich biological productivity, it must be provided the
maximum protection possible from new activities within that
area that would impact on the benefical uses of the area for
commercial and recreational activities and scientific research.
Therefore, it is our recommendation that all offshore oil and
gas development be banned within the boundaries of the sanctuary,
should it be created, and all dunpinq of wastes (e.g., radioactive,

STEWARDS OF THE FISHERIES

Ms. Vickie Allin
9 October 1987
Page Two

toxic, dredge spoils) be prohibited.

Thank you for this opportunity to comment and provide
recommendations. If you or your staff have any questions,
please do not hesitate to call.

Sincerely,

W.F. k-" Grader, Jr.
Exec. i e Director

WFG:lrb

cc: Honorable Douglas H. Bosco
Honorable Barry Yeene, Chairman, Joint Committee on Fisheries
& Aquaculture
Honorable Dan Hauser, Vice-Chairman, Pacific Fisheries Legislative
Task Force
Mr. Edward Wilczynski, Department of Commerce
Pacific Fishery Management Council
National Marine Fisheries Service
California Department of Fish & Game
California Coastal Commission

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Telephone (4 r8 6 8 al 201,Ar A
October 8, 1987

Paul H Wolff
Assistant Administrator for Ocean Services
and Coastal Zone Management
tional. Ocean Service, NOAA
1825 Connecticut Avenue NW
Washington, D. C. 20230

Dear Mr. Wolff:

Thank you for providing us the opportunity to respond to the Draft
EIS,MP for the Cordell Bank National Marine Sanctuary, Conceptually, the
EIS is logically laid out. We fully support the establishment of the
Cordell Bank National Marine Sanctuary, with the minimum boundaries as
noted in the preferred alternative proposal, and we endorse the research I. See Generic Response A.
and education plans as contained in the preferred management alternative.
We strongly urge that the final resource management plans for the Sanctuary
ensure the minimum disturbance of the natural resources and habitats to be
protected under the proposed National Marine Sanctuary.

The three main goals of research, monitoring, and, especially,
increasing public awareness of the Bank (p. 30) are desireable but require
accurate, up@to-date Information for success. The zany inaccuracies In the
Draft EISIMP, however, generate some apprehension reletive to these goals.
Examples of such inaccuracies include: 2. 1he current name of the Sanctuary is the Gulf of the Farallones National
p. 10 & throughout. Use of name, Point Reyes--Farallon Islands National Marine Sanc. Ha6ever, at the tirne of writing Of the DEIS/MP for Cordell
Marine Sanctuary, Is not current. it is the Gulf of the Farallones Bank National Marine Sawtuuy the old nam was still in use. To be
National Marine Sanctuary. consistent, during the designation Process for Cordell Bank, the old name of
Point Reyes-Farallon Islards National Marine Sary_tuayy will be used.
p. 18. Stoma come from west, with winds from south (30-40 knots); 3. This addition has been made in the FEIS/Mp.
prevailing northwesterlies blow strong March-July (regularly to 30
knots).
p. 18-19. Upwelling occurs year round but is most persistent -spring 4. 'This correction has been made in the FEIS/Mp.
and summer.

Jets of upwelled water, particularly from Bodega Canyon (just to the
north) often extend more perpendicular than parallel to average
southward flow of the California Current. These Jets of recently
upwelled water may account for periods of increased water clarity. 5. This correction has been made in the F'EIS/Mp.
p. 19. "Visibility about always >65 feet- is a statement applicable only 6. The Stateffent has been deleted fran the FEIS/Mp.
to autumn.

The statement: "animal poplation depends on the food provided by these
[red) algae" is false. Probably most of the benthic animals (except in
fauna) are filter feeders which depend on plankton. Next paragraph is
more accurate.

p. 22-23 List of fish Is woefully incomplete. Constitutes a list 7. Me lists and taLbles of species Presented in the DEIS/Mp is nt4nded
obse;-11.d by Schmeider only. The list should be checked with the "Plifiltile and not -diaustive to be
- Hclw--er additions have been made to the
71 National Marine Fisheries Service, Tiburon Lab. Fishes Identified in Cordell Bank Vqate,. in ,
the NWS Tiburon laboratory. I'able 1, based On discussions with
p. 29. Incomplete page. 8. The missing text has been added to the FEIS/MP.
p. 30. Third paragraph. Interesting statement in that the rockfish
species which Briggs et al. (1985) describe as being so important to 9- This fish species is ccumn in the diet Of the birds in the Central
birds (S. Jordani) Is missing from Table 1! It should either be Californian area but no mention is made in Briggs et al. (1985) that
Include7d or the inconsistency removed. 'Ordan' was identified in the COrdell Bank area. Therefore it has riot been
p. 31. Many inaccuracies in Table 4, as indicated. added to Table I.
p. 33. Paragraph 1. We suggest you check the assumption that rockfish lo' These' ina-cies ha-e been cOlre&-d in Table 4.
dominate the commercial catch. Confirmation should be made with NMFS ll. This Statement has been confirmed with the California Fish and Game.
Tiburon Labs. P-CUISh species - c-.b-.ed they cmpri. the largest portion of the Men all
by weight by -mWarcial fishermen at Bcdega Bay and San Fancisco POrts catch
p. 46-47. In preceding pages emphasis was given to the benthic communities
of Cordell Bank (which is justified), but also to rockfish, marine
mammals (whales especially) and plankt1vorous seabirds (Cassin's
Anklet).

Assuming that this emphasis was by design, a priority for baseline
research should be an attempt to understand the dynamics of euphausiids
as affected by physical oceanographic processes in the proposed Cordell
Banks National Marine Sanctuary as well as in the Gulf of the
Farallones National Marine Sanctuary. Euphausiids are a key component
in the food web and are especially important in the diets of several 12, ommient accepted, NW acalrages the input of all local e @,se in the
discussion of futum research projects an XP
pecies of abundant rockfish, salmon, whales, and planktivorous d Priorities for funding of
:eabirds (NMFS & PRBO unpubl. data). For the past few yearst NMFS- SanubkuT research and planning.
Tiburon has been researching the spatial and temporal dynamics of
euphausiid abundance in the Sanctuaries, but In a woefully under-
supported, though valiant, effort.

p. 48. A study of Northern (Steller) sea lions, such as the effort
described, is not feasible and should not be undertaken. It requires 13- 0--t accepted_ Any studies of Nr-@ lions or any th, res
131 study of diet which cannot be accomplished without much disturbance to Project will only be undertaken In the Sanctuary by highly qualified "rch
the already precariously small number of sea lions. Personnel after extensive review by relevant parties.
We hope that you may correct these inaccuracies in future reports.
Again, thank you for the opportunity of contributing our comments on and
support for this important proposed National Marine Sanctuary.

Sincerely yours,

rn
Executive Director

TABLE 4: Seabirds Observed on Cordell Bank

Brachyramphus marmoratus .................... Marbled Murrelet
Brenta bernicla ............................. Brant
Catharacta maccormiicki ..................... South Polar Skua
Cerorhinca monocerata ....................... Rhinoceros Auklet*
Cepphus columba ............................. Pigeon Guillemot*
Diomedes nigripes ........................... Black-footed Albatross
Synthliboramphus hypoleucus ................. Xantus' Murrelet
Fulmarus glacialls .......................... Northern Fulmar
Gavin arctica ............................... Arctic Loon
G. immer .................................... Comuon Loon
U. Tit-ellata ................................. Red-throated Loon
Larus argentatus ............................ Herring Gull
U-.californicus ............................. California Gull
L. canus .................................... Mew Gull
L 'Ke-ermanni ................................ Heemann's Gull
1@. hyperboreus .............................. Glaucous Gull
L. occidentalis ............................ Western Gull*
L. Philadelphia ............................. Bonaparte's Gull
L. thayeri .................................. Thayer's Gull
Phalaropus lobatus .......................... Red-necked Phalarope
P. fulicaria ................................ Red Phalarope
Tratercula cirrhata ........................ Tufted Puffin*
Oceanodroma homochroa ....................... Ashy Storm-Petrel
0. furcata .................................. Fork-tailed Storm-Petrel
U. Ye-ucorhoa ................................ Leach's Storm-Petrel
0. melania .................................. Black Storm-Petrel
feiTc-anus occidentalis ...................... Brown Pelican
Phalocrocorax auritus ....................... Double-crested Cormorant*
E. peligious ................................ Pelagic Cormorant*
P. penicillatus ............................. Brandt's Cormorant*
Ptychoramphus aleuticus ..................... Cassin's Auklet*
Puffinus carneipes .......................... Flesh-footed Shearwater
P. bulleri .................................. Buller's Shearwater
P. creatopus ................................ Pink-footed Shearwater
E. griseus .................................. Sooty Shearwater
P. puffinus ................................. Manx Shearwater
P. tenutrostris ............................ ShDrt-tailed Shearwater
Rissa tridacTy-la ............................ Black-legged Kittlwake
Stercorariu@ parasitus ..................... Parasitic Jaeger
S. pomarinus ................................ Pomarine Jaeger
Sterna forsterl ............................ Forster's Tern
S. hirundo .................................. Comaon Tern
S@ Pa adisaea ............ Arctic Tern
ntUiboram-p.h.u.s.a.-n.tlq**u*u*s.*'**.':: ............ Ancient Murrelet
Uria aalge .................................. Common Murre*
Xema sabini ................................. Sabine's Gull

*Species that breed on the Farallon Islands.

Corrections to R. W. Schmeider, 1985a.

San Francisco State University Department of Biology
1600 Holloway Avenue 415/338-1548
San Francisco, California 94132

Ms. Vickie Allin, Acting Chief
Marine and Estuarine Management Division
Office of ocean and Coastal Research Management
National Ocean Service/NOAA
1825 Connecticut Avenue, N.W.
Washington, D.C. 20235 October 9, 1987

Dear Ms. Allin:

For the past several years my students and I have studied marine
mammal distributions in the area of Cordell Bank and the Gulf of
the Farallones. We are currently preparing two manuscripts
concerning the work to date and look forward to continued
research in this region. I have studied the draft statements
with respect to establishing the Cordell Bank National Marine
Sanctuary and am writing to you to indicate my support for the
following aspects of the proposals:

1. Boundary Alternative #1' including the waters surrounding
Cordell Bank, is the appropriate alternative in establishing this 1. See Generic Response A.
sanctuary. Lesser areas would be inadequate to the goals of the
program.

2. This designation should absolutely and totally ban ALL
hydrocarbon activity within the sanctuary boundary from the
inception of sanctuary. The irreplaceable resources of this area 2. See Generic Response B.
might take decades to substantially recover from accidents
associated with such activity, and the proportionately minuscule
return in terms of human fuel production does not begin to
justify this risk.
3. Thereishould be substantial provision for on-site monitoring 3. See Generic Response G.
in the f nal document, with adequate funding for this work.

4. Contact with shallow ridges in the Cordell Bank area,
including anchoring of vessels, should be specifically 4. See Generic Response D.
prohibited.

Thank you for taking time to consider my suggestions. All of us
in my research group look forward to continuing to study the -,- A-16-,
',- I
unique wealth of natural resources in the Cordell Bank are'@v 11%
Sincerely
OU

Hal Markowitz, Ph.D.
Professor
The Citv's I lniver<irv A

SIE UB
C 1A
1228 N STREET, SUITE 31, 0, CA 95814 (916) 444-6906

October 12, 1987

Ms. Vickie Allin, Acting Chief
Marine and Estuarine Management Division
Office of Ocean and Coastal Resource Management
National Ocean Service/NOAA
1825 Connecticut Avnue, N.W.
Washington, D.C. 20235

Dear Ms. Allin:

The Sierra Club of California supports the establishment of the Cordell Bank
National Marine Sanctuary.

Cordell Bank's unique combination of nutrients, ocean currents and sunlight
penetration allows it to support many different marine creatures. Unfortunately,
it is also very vulnerable to accidents involving off-shore drilling, tanker
spills and ocean dumping.
rwe urge the establishment of a marine sanctuary in the Cordell Bank using 1. See Generic Pisponse A.
U
oundary Alternative #1. We also urge the prohibition of all offshore
0 il and gas exploration or development within the whole sanctuary boundary. 2. See Generic Response B.

Thank you for your consideration in this matter.
Sin@@rely,
/-,/ - /_

M. L. Mesmer
Wildlife Committee Co-Chair

cc: Senator Alan Cranston
Senator Pete Wilson
Congresswoman Barbara Boxer
Congresswoman Nancy Pelosi
Congressman Douglas Bosco
Interested parties
$e OCT

2410 BEVERLY ULVD., LOS ANGELES, CA ,XX)57 6014 COLLEGE AVE., OAKLAND. CA 94618 730 POLK ST, SAN FRANCISCO, CA 94 1

Loma Prieta Chapter, Sierra Club
2233 Park Blvd.
Palo Alto CA 94306 September 25, 1987

Ms. Vickie Allin, Acting Chief. Marine and Estuarine Management Division
OCRM, National Ocean Service/NOAA, 1825 Connecticut Avenue, NW
Washington, DC 20235

Mr. Edward Wilcynski, Acting Chief, Ecology and Conservation Division,
U.S. Department of Commerce, Room 6814, Washington DC 20230

Mr C William Verity, Jr., Secretary Designe, U. S. Department of Commerce
Washington, DC 20230

Gentlemen:

This Chapter of the Sierra Club strongly supports the creation of the
proposed Cordell Bank National Marine Sanctuary. Few spots in our 4 billion
acre OCS are blessed with the environmental advantages, particularly the
nutrient rich water, required to support such an abundance of fish and
wildlife.

We urge the adoption of "Boundary Alternative #1" which will provide 1. See GenEric Response A.
the broadest area of protection. We also urge a full ban on all OCS oil and 2. See Generic Response B.
qas drilling activities from the beginning.

cc Very truly yours,
Georgia Perkins
Rod Holmgren
Richard Charter
WiIIiam S Morris, Chair
OCS Committee

-.,.,SIERRA CLUB MARIN GROUP
Box 422, Inverness, Ca. 9493q?

October 9, 1987

Ms. Vickie Allin. Acting Chief
Marine and Estuarine Management Division, 0CRK
National Ocean Service/100AA
1825 Connecticut Avenue N.V.
Washington, D.C. 20235

Res Proposed Cordell Bank National Marine Sanctuary

Dear Me. Allins:

The executive committee of Sierra Club Karin Group. at its regular
meeting In October. unanimously approved the following motions;

-- We support establishment of the Cordell Bank National Marine
Sanctuary as a means of protecting valuable marine resourceel
-- We support the "Boundary Alternative #1* establishing an area 1. See Generic Response A.
of about 397 square miles because it will thus adjoin the existing
Gulf of the Farallones National Kerins Sanctuary and will provide
the needed continuity of protectiong and 2. See Generic Response B.
;; We strongly support a ban on oil and gas leasing, exploration
and development activities as part of the regulatory framework for
the entire Cordell Bank National Marine Sanctugry from the beginning
of its exiortence.

Cordell Bank lies off the coast of Marin County, as does the Gulf of
the Farallones National Marine Sanctuary. We believe that needed
protection for the whales, sea birds and valuable fisher*,resources
will be best achieved by adoption of the new marine sanctuary with
boundaries and preservation from oil or gas development as described
above.

Sincerely,

Sierra Club Merin Group
Anne West, Secretary

ces Edward Wilcynaki, Ecology & Conservat U.S. Dept. bf Commerce
C. William Verity. Jr.. Secretary Designe, U.S. Dept. of Commerce

"We shaft require anew manner of think hm ifmankind is to survive." -AlbertEinstein

MATTHEW A. BAILEY
P.O. B.. iss
Dw.h F1.1, Uif-i. 05714
(916) a89-2354
October 12, 1987

Ms. Vickie Allin, Acting Chief
Marine and Estuarine Management Division
Office of Ocean and Coastal Resource Management
Washington, D.C.

Dear Ms. Allin,
In behalf of the Mother Lode Chapter of the Sierra Club, 1 1. See Generic Response A.
wish to express support for the proposed Cordell Bank National 2. See Generic Response B.
Marine Sanctuary, west of Point Reys, California. In addition we
support Boundary Alternative #1 and the prohibition on oil and
gas development within the boundary.

We feel it is important that this unique ecological community
this special protection.

Chairman,
Wildlife Comm2qle.
Mother Lode Chapter
Sierra Club

1314Zsza

"V_x

SAN FRANCISCO BAY CHAPTER-SIERRA CLUB
AIM,IJ HA (it,A - MARIN ,AN f HANGIM.U "014 (.01 L I (X, AV[,NLJi (AKi AN) ( A
10 )OK ("iL 7.110 01 1 (F W" o"i (.( NSE NAIH@)N

September 24, 1987

Ms - 'ickie Allin, Acting Chief
Marine and Estuarine Management Division, OCRM
Nationa1 Ocean Service/NOAA
1825 Connecticut Avenue, N.W.
Washingt on, DC 20235

Dear Ms. Allin,

The San Francisco Bay Chapter of the Sierra Club heartily
supports the creation of the proposed Cordell Bank National
Marine Sanctuary. Preservation of this unique marine environment
offers a vital opportunity to protect our threatened marine
resources. Cordell Bank is an "undersea island" with associated
subsea rocky pinnacles. The combined factors of shallow depth
allowing a high degree of light penetration for photosynthesis,
and high nutrient concentration transported by local upwelling
and surface currents creates a unique habitat for a wide variety
of organisms. Thirty-eight species of fish inhabit Cordell Bank.
Fourteen species of marine mammals, and at least forty-seven
species of seabirds use the waters surrounding Cordell Bank as
feeding grounds. Four endangered species, the humpback whale,
the blue whale, the Brown pelican and the short-tailed albatross
have been observed near Cordell Bank. This new Marine Sanctuary
would provide an fascinating opportunity for scientific research
and public education.

An important aspect to the creation of the Cordell Bank
National Marine Sanctuary is the inclusion of an appropriate
buffer zone around the Cordell Bank. The designation of Boundary
Alternative #2 preserves only the immediate Bank environment and
does not afford adequate protection from pollutants or other
hazards that could easily drift into the sanctuary. Take the
example of the 140 mile drift of the oil spill from the tanker
Puerto Rican in 1984. The minimal area surrounding Cordell Bank
in Alternative #2 offers no assurance of protection in the case
of similar accidents or even accidents of a much smaller scale.

'I'l @% 2 @j 1ppp
46
WOW

It also leaves an unprotected gap between the new sanctuary and
the pre-existing Gulf of the Farallones National Marine Santuary.
The choice of Boundary Alternative #1 not only offers a more
appropriate buffer zone around the Bank, its boundaries would
adjoin the existing Marine Sanctuary offering continuity of
rotection for the entire area. The designation of Boundary
P"
LA11ternative #1 thereby is the more logical choice for preserving
tk
the Cordell Bank. 1. See Generic Response A.
As a National Marine Sanctuary, Cordell Bank requires
absolute protection from potentially disastrous activities
associated with oil and gas exploration and development.
Interior secretary Hodel's "deferred" area protects only the
central core area of Cordell Bank and is only temporary. There
iB no assurance that the "deffered" area will continue to be
@rotected after the five year period of his OCS Program. it is
herefore vital that a full ban on all OCS oil and gas leasing
and drilling activities be included in the regulatory framework 2. See Generic Response B.
of the Cordell Bank National Marine Sanctuary from the
beginning.

The unique environment and rich concentration of marine life
of Cordell Bank warrant preservation under the Marine Protection
Research and Sanctuaries Act. The San Francisco Bay Chapter of
the Sierra Club urges you to support the creation of Cordell Bank
National Marine Sanctuary, adopt Boundary Alternative #1 and ban,
from the beginning, all OCS oil and gas leasing, exploration, and
development.

Thank you for considering our comments.

Sincerely,

Dana Kokubun
Conservation Representative

DK/mf
cc: Jane Preskienis

SONOMA COUNTY GROUP
REDWOOD CHAPTER
CLUS

319 Gate Way
Santa Rosa, CA 95401
October 5, 1987
ft. Vickie Allip, Acting Chief
National Ocean Service/40AA, Marine and Estuarine Management Divisioll
Washington, D.C. 20235
re: proposed Cordell Bank National Marine Sanctuary
Dear Ms. Allin,
The Sierra Club Sonoma Group would like to express our wholehearted Support
for the creation of the Cordell National Marine Sanctuary. This rich undersea
area supports a great dea of marine life which is increasing impacted directly
by such activities as commercial and sport fiqNnR and boating. as voll 4,-,
indirect impacts from shipping (e.g. waste and fuel discharges and spills)
anti petroleum exploration (e.g. seismic testing, drilling mud discharges,
hdr, a, "a sp s q"C,q)* D , e nearby location and interrelated ero-
0 nc " q"' ' L a 'o r,
tems (as exemplified by marine mammals and s4i@abirds) with the Farrallon
atids, we recommend that Alternative #1 be ebusen as the boundary @or the
sanctuary @z@ that the two areas are connected and no potentially disturbing I. -See Generic Response A.
ivity can take place bermpen them.
;524qE
We also highly recommend that oil and gas exptoration and drilling be
ifically excluded from the proposed Sanctuary. The current 5 Year OCS 2. seo@! Generic Respm)se B.
sing Program does include areas that are much too close to the actual sea-
60q-L-8qneq,
mount, especially when you consider that such activities have considerable
@'spillover''' such as air pollution. drilling mud discharges, petroleum spills
and leaks. All of these "spillovers" can have major impact on a wide variety
of marine birdta and mammals. it dQQs not make 6eqse to wait to
soo what happens on future lease sales to detiiie, what kind of protection is
noc-ded for the Sanctuary-W, know now that oil and gas drilling is coapletq0y
innappropiate for the Marine Sanctuary. Therefore, surh protection should be
written ij@ from the beginning.
Thank you for this opportunity to comment an this proposal.

Sincerely,

Michael Krikorian, Chairman
Conservation Committee
tilt Sierra Club Sonoma Group
4qRqEqI0qVqIqO

@qiqgc-f 8q@41

W
Texoco USA P0 Ek' 2'()o
Cenual Explotation Dwiw.n ne-er CO 80201
4601aTC Bouleva,d
Denve, CO 80237

September 17, 1987

RELOCATION OF TEXACO'S LOS ANGELES OFFICE

NOAA/NOS/OCRM
Marine & Estaurine Management Division
1825 Conn. Ave., N.W. Suite 714
Washington, D.C. 20235

Dear Sirst

Effective immediately, Texaco has relocated its Universal City, CA
exploration offices to Denver, Colorado. I will continue as Project
Leader for the Offshore California Exploration Group. I report to Mark No ReS1q- Neoessary.
Cole. who is Regional Manager for the Southern Exploration District which
includes, besides the California offshore, the California onshore and
the Permian Basin. Mark reports to York LeCorgne who is Exploration
Manager, who in turn reports to Joseph Butera, Central Exploration
Division Vice President. Our office is located at the Denver Tech
Center. The address is:

C. M. Clayton
Texaco Inc., Rm. 821
Offshore California Project
4601 DTC Blvd.
Denver, CO 80237
(303) 793-4268

Please update your records to reflect these changes. We look forward to
continuing our relationship with you in our California OCS activities.

Sincerely,
(1 -q?q7q1 - 6q0q"q@0qv "I.-q-qI4q@q;C6q@
C. M. Clayton

CMC:jat

u
nclerwater photography research
Ron Russo
marine biologist

October 7, 1987

Dear Me. Allin:
I. See Generic Response A.
I - I ting in support of Boundary Alternative #1 and for
@.,,...plete b!n on all hydrocarbon activity within the sanctuary 2. See Generic Response B.
undary at Cordell Banks. I also think such provisions must be
so t of the sanctuary designation documents. Further, it is 3. See Generic Response G.
tion that the Cordell Banks is a rare and unique national
3 that requires additional funding for on-site monitoring, 4. See Generic Response D.
-0
r

tprovisions are added that bans all contact with the
ps by anchoring. I urge you to make sure these measures
treas L uately addressed in the enabling legislation, agreements.
and t
rridg to
.r. :dq
and laws.

Cordell Banks requires stringent protection from economic
interest. As a marine biologist, I an acutely aware of the
significance of the discoveries made at the Banks. Oil exploration
and drilling in the area can only have disastrous results for what
we are beginning to understand is an underwater island of unique
life form.

Please act to ensure the implementation of these measures.

Sincerely,
/Ia? 12--l-I
Ron Russo
Chief Naturalist
East Bay Regional Park District
RR/dm
--ii4lor,

OCT 1W

Ms. Vickie Allin,
Acting Chief
Marine and Estuarine Management Division, OCRM
National Ocean Service/NOAA
1825 Connecticut Ave, NW
Washington, DC 20235 September 26, 1987

Bear Ms. Allin,

I am writing in support of the creation of the Cordell Bank National Marine
Sanctuary. The proposed sanctuary represents a unique ecosystem along the
coast of North America - a temperate marine offshore bank. Its uniqueness
is underscored by not only the unusual concentration of marine biological
diversity but by new species of benthic fauna that have been discovered
there, as well as observations of previously unrecorded species for this
area and endangered species (the humpback and blue whales, the brown
pelican, and short-tailed albatross).
Q
ch an ecological treasure deserves the best protection our government can 1. See Generic Response A.
ve it, which is why I am strongly urging that Boundary Alternative #1 be
opted to create a sanctuary with a good buffer zone. The need for such
ffer zones becomes more important everyday, especially with the projected
increase in offshore oil/gas development (entailing pollution from the
disposal of drilling muds) and with every new oilspill. This alternative
has the added advantage that its boundary would adjoin the existing Gulf of
Farallones Sanctuary on two sides, providing an important continuity of
protection not provided by Alternative #2. This alternative, if adopted with
Management Alternative #2, would combine management and administration of
these two sanctuaries and thus provide the most economical and effective
method of experienced management to Cordell Bank.
ides adopting these alternatives, the bank critically needs a ban on OCS 2. See Generic Response B.
and gas leasing, exploration, and development activities as part of the
Qctuary's regulatory make-up from its very inception. Sec. Hodel's
ferred" area is too limited to adequately protect the bank's resources
and is only temporary. Furthermore, the Secretary's past record of
negotiation to balance environmental and energy concerns suggests that he
cannot be counted on to ensure adequate protection of our environmental
resources.

I strongly urge that this ban and these alternatives be adopted. Just one
bad accident could wreak possibly irrevocable havoc on this unique
ecosystem; it is important that we do al I that we can to prevent such an
event from happening.
I'd appreciate your comments; s@ includfxg this letter the public
record. Thank you.

Sincerely,

Dr. Mary Ellen Harte
address: 1180 Cragmont Ave Research Associate,
Berkeley, CA 94708 '.Onfifiersity of California at Berkeley

UNIVERSITY OF CALIFORNIA, DAVIS

BEMELEY - D-JS - IRVINE - LOS ANCELES - -@IDE - SAN DIECO - SAN -CISCO SANTA D-ARA SANTA CRUZ

BODEGA MARINE LABOKATOR) P 0 BOX 241
(707) 875-2211 BOVEGA BA I. CAI IFORNIA "92@

6 October 1987

Dear Ms. Allin:

Within the Draft Environmental Impact Statement/Management Plan marginal
justification appears given for the establishment of the Cordell Bank National Marine
Sanctuary (CBNMS). The invertebrate fauna on the bank is composed of both intertidal
and subtidal species in zones separated by depth. At its shallowest, the bank is 19
fathoms, a deep and barely feasible sport dive. Over the bank is a diverse community
of fishes including many rockfishes. Pinniped and cetacean species are listed as
sighted at the surface above the bank. Yet I am unsure whether all of these species
are sighted more often here than anywhere else along the coast of Northern
California. Hopefully, these faunal attributes will attract enough public attention
to justify the tax funds spent in management and administration of the Sanctuary.
If a sanctuary is established, Alternative 1 would provide the best boundary. 1. See Generic Response A.
Gi. would adjoin the boundaries between the CBNMS and the Point Reyes/Farallon
Islands National Marine Sanctuary (PRNMS). Both areas are not that different:
shallow areas abound in the area between Southeastern Farallon Island and Cordell
ank. Is it really necessary to separate the two sanctuaries and give them different 2. The two sanctuaries each contain uniquely distributed resources that require
names? cAlternative 2 may be the more appropriate and less costly mangement strategy, different types of regulation and protection. However the management
i.e., ombining the management and administrative system of the CMNMS with that of structure will be the same for both Sanctuaries enabling a minimizing of
the PRNMS. additional resources to mianage the new Cordell Bank National Marine Sanctuary.
Cordi 1@y yours,*

A. Peter Kli ley, Phi ,D.
Asst ' Res. Behaviorist

c.c.: Mr. Paul M. Wolff, Assistant Administrator for Ocean Services and Coastal Zone
Management, National Ocean Service, NOAA.

I-

qr
#V
IV

Unocal Corporation
120 1 West 5th Street, PO Box 7600
Los Angeles. Ca"1011118 91,051
T.I.ph- 1213) 9717 6810
ES87 -163 6q@30 q41
'q0
UN8qOCAL6qS
R

C deton S. Scott 987
D1,10,x. E-F.111-111.1 September 24, 1

Ms. Vickie A. Allin
Acting Chief
Marine and Estuarine Management
Division
National Ocean Service/NOAA
182S Connecticut Avenue, NW
Washington, D.C. 2023S

Dear Nis. Nllin-.

The National Oceanic and Atmospheric Administration (NOAA)
recently proposed Cordell Bank National Marine SanLtuary
regulations (52 FR 32S63). In response to this publication and
NOAA's request for Lomments on "Cordell Bank National Marine
Sanctuary: Draft Environmental Impact -Statement/Management Plan
(May 1987q)", hereinafter referred to as the DEIS, the Union Oil
Company of California (UnOLal) takes this opportunity to
comment.

Unocal is a fully integrated, high technology earth resources
company which, in part, explores for, deve lop s and produces
conventional crude oil and natural gas resources in the United
States, Canada and overseas. Unocal, therefore, is very
concerned with any action that potentially offers to limit
at-cess to lands, either onshore or offshore, that may possess
hydrocarbon resources.

Unocal supports the designation of the Cordell Bank National 1. See Gerieric Response A.
Marine Sanctuary. This support is conditioned on NOAA's
inclusion of the identified preferred actions in the Final 2. See Gerieric Response B.
n
Environmental Impact Statement/Management Plan and final
regulations. Specifically and as set forth in the DEIS on
pages 73-74, there should be no immediate regulation of
[hydrocarbon development activities.

Ms. Vickie A. Allin
Acting Chief
Marine and Estuarine Management Division
September 24, 1987
Page Two

Cordell Bank is not at present subject to leasing and the area
of Cordell Bank within approximately the fifty-fathom contour
has been excluded from the Department of Interior's five-year
plan for the OCS Leasing Program (DEIS, page 73). In addition,
and prior to any hydrocarbon production in the area, three
additional Environmental Impact Statements/Assessments
(EIS/EIA) must be developed. These are the Lease Sale EIS, the
Exploratory Plan EIS/EIA and the Development Plan EIS. Each of
these documents represents a process which provides for
additional public input and scientific review. Specific
permits associated with petroleum development activities, i.e.,
NPDES permits for discharges to marine waters and Corp. of
Engineers 404 permits with Clean Water Act section 401
certifications, plus reviews conducted in compliance with the
Endangered Species A(-t and the Marine Mammal Protection Act are
intended to minimize and limit the adverse ecological impacts
of OCS activities. Finally, should NOAA determine that
protective criteria advanced through these statutory activities
are insufficient to comply with the mandates of the Marine
Protection, Research, and Sanctuaries Act, NOAA may promulgate
emergency regulations or propose permanent regulations (52 FR
32563). Thus, the current exclusion of Cordell Bank in
combination with existing statutory mechanisms support NOAA1s
preferred alternative. The immediate regulation of hydrocarbon
development activities in the proposed Cordell Bank National
Marine Sanctuary is unwarranted at this time.

Unocal appreciates this opportunity to comment on NOAA's
proposal as expressed in the DEIS and 52 FR 32S63. Should NOAA
desire any clarification of these comments please contact
Mr. Robert J. King, Jr. at (213) 977-6424.

Sincerely,

CBS:ss

cc: Mr. Edward Wilczynski
Acting Chief
Ecology and Conservation Division

3297k

Whale Center
NATIONAL OFFICE
3929 Piedmont Avenue, Oakland, California 94611
(415) 654-6621
WE WORK FOR THE WHALES AND THEIR OCEAN HABITAT
@d."dmd.Aly 1A, Md-d-q...In-f,p@ tu-d mpooed protection 4 ie-,tro,toiewthe ioo,
'-'t '."t @ '-b1,d e.tN into the 2 14 ant.,y.
From the (dobal 2000 Report to the Pre,idrot

Ms. Vickie Allin, Acting Chief October 6, 1987
Marine & Estuarine Management Division
Office of Ocean & Coastal Resource Management
National Ocean Service
NOAA
Washington, D.C. 20235

Bear Ms. Allin:

Enclosed for the record are the comments on the proposed designation 1. See Generic Response A.
of the Cordell Bank National Marine Sanctuary and draft EIS.

Thank you for your consideration of our views. We strongly support
the sanctuary, but we feel equally strongly that all oil and gas exploration 2. See Generic: Response B.
0q1 and development activity should be banned from the sanctuary boundary.

Sincerely yours,

Mark J. Palmer, Administrator

qUqCT DR,

Whale Center
E NATIONAL OFFICE
TE 3929 Piedmont Avenue, Oakland, California 94611
(415) 654-6621
WE WORK FOR THE WHALES AND THEIR OCEAN HABITAT
tA, bold a.d i-g ... tt@. 0,p t",d mp-d ;,Wuho-t the @,Wd
t..bW,.ty,w. the
Fw. the Glhisl 2000 R,NH t@ the P,esnkw

WHALE CENTER STATEMENT OF SUPPORT FOR A CORDELL BANK NATIONAL
MARINE SANCTUARY Sept. 30, 1987

The Whale Center has been a strong supporter of the development of

the National Marine Sanctuary System of the Department of Commerce. We

have helped establish the two California sanctuaries, the Channel Islands

National Marine Sanctuary and the Gulf of the Farallones National Marine

Sanctuary. We have further helped develop and promote education programs,

research projects, and interpretive tools for our local sanctuary.

The Whale Center strongly supports the designation of Cordell Bank

of California as a National Marine Sanctuary. This spectacular pinnacle

of undersea geography and living gardens, of feeding grounds for whales,

dolphins, and marine birds, deserves national recognition and the fullest

protection possible.

However, we are concerned with some aspects of the Draft Designation

Document and Environmental Impact Statement. We feel some aspects of the

preferred alternative do not provide sufficient protection for the Cordell

Bank area.

Sanctuary Boundaries:
The preferred alternative boundary III Alternative, Boundary Alternative 3. See ReSPO- No. 1.
CEN

2) would provide protection for the core pinnacle area of Cordell Bank and
3 an area
the feeding area of marine mammals and birds by encompassing 3 miles beyond
A
the 50 fathom isobath. Boundary Alternative 1, on the other hand, does have

advantages from a management standpoint. This alternative links up the

northern extension of the Gulf of the Farallones National Marine Sanctuary

at Bodega Head with the northern extension of the Cordell Bank area, providing

a complete, contiguous sanctuary boundary subject to regulation and control

in a much more logical boundary. We urge the Commerce Department to consider

the larger boundary from a management standpoint, to ensure that the whole

coastal and Cordell Bank/Farallones ridge are protected.

Offshore Oil Restrictions:

The Draft Environmental Impact Statement discusses the concerns

about Offshore Oil Exploration and Drilling on pages 34, 42, 73, and 84-85.

At present the Draft Designation Document proposes no regulations to prohibit

oil and gas activity in the Sanctuary. Instead, reference is made to the 4- See ResPOnse No. 2.

OCS 5 Year Plan developed by the Department of Interior's Minerals Management

Service. We feel this protection is totally inadequate, and urge that the

Commerce Department either draft a regulation to exclude oil and gas development

from the Sanctuary or amend the 5 Year Plan to exclude OCS activity from the

Sanctuary.

Under the OCS 5 Year Plan, oil and gas exploration and drilling are

only deferred "within the 91 meter (49.76 fathoms) isobath" (DEIS page 34).

The preferred alternative (Boundary 2) would extend for 3 miles on all

sides of this core area. Within this buffer zone, the prime feeding habitat

for marine mammals and birds (including 3 endangered species -- the humpback

and blue whale, and the brown pelican), "(M exploration and development

activities were to occur in the area beyond the fifty-fathom zone, they
could be monitored to assess the likelihood of spills. Precautions could
minimize
be taken toA spill-risk and to improve contingency planning to reduce
the impact of any spills that did occur." (DEIS page 84-85).

These statements are totally inadequate. We strongly feel that all

OCS activity should be excluded from the Sanctuary boundary, as is the case

now with the other two existing California National Marine Sanctuaries.

We are at loss to understand why Cordell Bank does not have the same

protections.

As we have seen from the explosion of the tanker Puerto Rican

and the recent sinking of the freighter Pacbaroness off Santa Barbara,
oil spills on the high seas cannot be contained under present tech.nology.

Sanctuaries like Cordell Bank should not be put at risk from the threat

of offshore oil drilling. In addition, current clean-up technology does

not deal with oil that sinks -- oil clean-up efforts are confined to dealing

with surface slicks. Therefore, any clean-up effort at Cordell Bank would

not even address the impacts on the subsurface benthic organisms that are

unique to the area. Furthermore, offshore oil drilling is conducted with
drilling muds containing many contaminants (including heavy metals) potentially

lethal to underwater filter feeding organisms characteristic of Cordell

Bank -- the DEIS makes no mention of this hazard. Sound pollution from

OCS activity has raised problems in the Beaufort Sea with bowhead whales.

In summary, the DEIS is inadequate with respect to the real hazards OCS

activity poses to the marine life of Cordell Bank, and the Draft Designation

Document does not provide the regulatory mechanism sufficient to protect

Cordell Bank from OCS activity.

To repeat, the Whale Center believes that oil and gas exploration

and development activities should be excluded from Cordell Bank National

Marine Sanctuary, and we urge the Department of Commerce to develop a regulation

identical to existing regulations for the two existing California National

Marine Sanctuaries.

4 -

Other OCS Issues:

The draft EIS proposes basing oil spill clean-up vessels and

contigency efforts in San Francisco Bay. The Whale Center suggests that

such vessels and gear should be based in Bodega Bay, as the harbor is

closer to Cordell Bank and more readily accessible due to prevailing

current and wind patterns. Clean-up efforts from San Francisco Bay will

be hampered by wind and sea conditions in approaching Cordell Bank.

We have already discussed above the problems with clean-up

technology relative to underwater resources like the benthic organisms

characteristic of Cordell Bank.

Of considerable concern with this regard are the proposals in

the Department of Interior's OCS 5 Year Plan for leasing and oil activity
exists
in the Bodega Basin north of Cordell Bank. The potential Afor oil spills
and other pollutants to be carried down to Cordell Bank by prevailing

conditions of wind and waves. While the regulation of OCS activity

outside of the Sanctuary boundary is beyond the scope of these hearings,

we did feel we should point out the problem, as problems beyond the control

of the Department of Commerce could render the sanctuary meaningless.

Staffing:

The Whale Center strongly supports adequate human resources to

manage Cordell Bank and the other sanctuaries in the system. The DEIS
does not, we feel, place enough attention on the need for monitoring of 5. See Gerieric Response G.
the sanctuary (particularly pollution incidents and illegal use of gill

nets). We also feel that Cordell Bank will provide a unique opportunity for

interpretation of the offshore areas of our coastline, and feel adequate

resources should be provided to develop public use of the Bank and public

understanding and education of the Bank's wonders. During the budget process,

adequate funding must be provided to fund activities for the Cordell Bank

National Marine Sanctuary and other sanctuaries.

In conclusion, the Whale Center strongly supports the proposal

for a Cordell Bank National Marine Sanctuary. We feel the larger boundary

range should.be considered. We feel very strongly that all offshoreoil
and gas exploration and drilling should be excluded from the sanctuary.

Adequate resources must be provided for management, interpretation, research,

and enforcement of protection at Cordell Bank and other National Marine

Sanctuaries.

We look forward to working with the Marine Sanctuary Office on

the Cordell Bank proposal -- it's been a long time coming! Thank you for

your consideration of our views.

For information on Cordell Bank, contact Mark J. Palmer, Whale Center@

3929 Piedmont Ave., Oakland, CA 94611 (415) 654-6621.

THE WILDERNESS SOCIETY

CALIFORNIAMEVADA REGION

October 8, 1987

Ms. Vickie Allin, Acting Chief
Marine and Estuarine Management Division
office of Ocean and Coastal Resource Management
National Ocean Service/NOAA
1825 Connecticut Avenue, NW
Washington, D.C. 20235

Dear Ms. Allin:

The Wilderness Society would like to comment on the
Draft Environmental Impact Statement, Draft Management Plan
and Proposed Rule for Cordell Bank National Marine
Sanctuary. This unique and fragile area must be protected
rom possible adverse human activities such as off-shore
drilling, tanker spills and ocean dumping. Therefore, we 1. See Generic Response A.
strongly support Alternative #2 and Boundary Alternative #2
to designate this area as a sanctuary.

We further request that the sanctuary regulations be
-trengthened by prohibiting any off-shore oil and gas
exploration and development withing the whole sanctuary 2. See Generic Pasponse B.
bou
;tE ndary.
Please keep us informed of your decision in this
matter.

Sincerely,

Patricia S iffer
Regional Direc1lor
California/Nevada

4bN
cc: Mr. Edward Wilczynski &10t
The Honorable C. William Verity
E 40
Senator Alan Cranston OLT 19V
Senator Pete Wilson AM vfg
Congresswoman Nancy Pelosi
Congresswoman Barbara Boxer
Interested parties

1791-A PINE STREEr. SAN FRANCISCO. CALIFORNIA 94109 T-ELEPHONE(415)771-2020

GOVERNMENT COMMENTS

JARBARA BOXER 101 CANNON BUILDING
qM DiSTRICT, CAUFORMA WASHING ON, DC 20515
4202)225-6161
DSTRICT OFFICES:
COMMINSION ON THE BUDGET 460 GOLDEN GATE AVENUE
SAN FRANCISCO, CA 94102
(41 5)626-6943
COMNIMEE ON ARMED SERACES 88 8ELVEDERE STREET
SAN RAFAEL CA 94901
SUE" COMMITTEE ON CHILDREN, 2qConqaqrqt4qa of the 2qanqitqeqb 6qOtqatqtqo '415145@4272
VOLFTK AND FAMILES 42 f STARR AVENUE
VALLUO, CA 945W
0q*ouqge of 6qReqpre8qantatqibefq; (7071652-0720
Vq" AT LARGE 2qMagqbinqgton, Adq: 20515 1707S)"7N6o3qWW33

September 30, 1987

TESTIMONY OF
CONGRESSWOMAN BARBARA BOXER
IN SUPPORT OF CREATION OF THE
CORDELL BANK NATIONAL MARINE SANCTUARY

As the Representative of the Congressional District adjacent to
the proposed Cordell Bank National Marine Sanctuary, I would like
to welcome this hearing panel to our District. I have long been
an advocate of the National Marine Sanctuary Program, and when I
served on the Marin County Board of Supervisors, I worked in
support of the creation of the present Gulf of the Farallones
Sanctuary now in existence.

This unique area is blessed with a rich and productive marine
environment, and the economic health of our local communities is
closely tied to the health of our coastal waters. At the local
government level, in the State Legislature, and in the Congress,
I think that you will find that we make the protection of our
coastal resources one of our very highest priorities.

It is within this context that I would like to express to you my
unlimited support for the creation of the proposed Cordell Bank
National Marine Sanctuary. Designation of this area as a new
National Marine Sanctuary is certainly in keeping with its status
as a national treasure.

Further, I would like to encourage adoption of the Boundary
Alternative One outlined in the Draft Environmental Impact 1. See Generic ResPonse A.
Statement. The broadest possible protection is needed for the
waters of Cordell Bank, and Boundary Alternative One provides a
complimentary format which matches the present Gulf of the
Farallones Sanctuary boundaries. To leave an unprotected gap
between the two Sanctuaries is highly inadvisable.

I have been part of the Congressional Negotiating Team which has
worked for the past two years with Interior Secretary Donald
Hodel, trying to convince him to moderate his offshore drilling
plans. I can tell you that, based on my experience in that
process, strong and contiguous administrative protctions are
needed for our coastal waters. To leave art unprotected gap

invites problems at a later date.

I also feel that it is extremely important to include a total ban
on all OCS development activities from the very outset, and to
apply this ban to all waters of the new Cordell Bank Sanctuary,
and not just to the Bank itself. Secretary Hodel is taking only
the narrowest interpretation of buffer zones in his new Five-Year
OCS Program. Quite frankly, his so-called buffer zones are 2. See Generic Response B.
insufficient in terms of providing any meaningful protection for
biological resources. To fail to provide an OCS development-
activity ban within the total Cordell Bank Sanctuary because the
Department of Interior has deleted the immediate Bank itself from
the new Five-Year OCS Program implies that we should trust the
Interior Department. I can tell you, again from direct
experience, that the Interior Department should riot be trusted in
these matters.

In July of 1985, the Secretary said that he wanted to protect
most of the central and northern California coast from offshore
drilling, including all of the waters around Cordell Bank. A
month later, Mr. Hodel changed his mind. He should have no
problem whatsoever accepting an OCS development ban within your
modest proposal represented by Boundary Alternative One. Such an
OCS development ban must preclude all exploration, leasing,
development, and pipeline construction. This area is, quite
simply, too sensitive to place at risk.

In conclusion, I would like to reiterate my appreciation to you
for holding these hearings on this timely proposal.

Thank you for your attention.

NANCY PELOSI
THE DISTRICT. CALIFORNIA BANKING, FINANCE
AND URBAN AFFAIRS
I- L-- B.IL-N GOVERNMENT OPERATIONS
W@-. DC 205 1 q"505
(2021225-4965 8qCqon2qgrqr6qa of the 2qNnitqeb 6qOtqatqtqo
.ST- I.C.
F.... 0 qJqOouqzqe of 0qAtqpr8qatntAtqiqbcqo
450 GOLIN. Oll, A@ ... I
m F-0. CA 941023460
(416) 566-4882 6qWAsqbqin4qvon, 4qMqC 20515-0505

October 9, 1987

Ms'Vickie Allin, Acting Chief
Marine and Estuarine Management Division
Of fice of Ocean and Coastal Resource Management
National Ocean Serv ice/NOAA
1825 Connecticut Avenue, N.W.
Washington, D.C. 20235

Dear Ms. Allin:

This is to add my comments to the public record regarding the
Draft Environmental Impact Statement for the Cordell Bank
National Marine Sanctuary.

This marine environment is known for its abundant natural resources,
including fourteen species of marine mammals and forty seven other
species of seabirds. The humpback and blue whales, now endangered,
are among these.

Designation of this area as a sanctuary would insure the preser-
vation of its recreational, ecological and esthetic values. It
would also address the important question of offshore energy develop-
ment by offering protection to this unique biological area.

According to the information I have reviewed, it appears that
Boundary #1 would offer the greatest protection to this area. 1. See Generic Response A.
'qEdditionally, I wish to stress the importance of restricting energy
exploration within this proposed boundary. Tragic events in recent 2. See Generic Response B.
years have highlighted the increased danger of oil spills and con-
tamination of marine life. It would be counterproductive to attempt
to create a sanctuary while, at the same time, allowing oil and gas
development within the boundary of the proposed Cordell Bank
8qLational Marine Sanctuary.
I hope you will keep these comments in mind as you review the DEIS
and that you will act to offer this area the maximum protection
possible.

Thank you for your consideration of this request.

Sincerely, 1,

0qaAA

NANCY PELOSI
@CA
Member of Congress

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SECRETARY'S OF I'- F
2qN1 OCT 20 M 11: 11 WASHINGTON. OC 205 10 q1qqq8qj 2q0 6qP 127 2q1
October 19, 1987 709725

The Honorable C. William Verity, Jr.
Secretary
Department of Commerce
Washington, D.C. 20230

Dear Mr. Secretary:

I am writing in support of the proposed Cordell Bank
National Marine Sanctuary off the coast of Northern California.

This unique undersea environment can provide an
outstanding "living laboratory" for scientific researchers and
for public education. The undersea pinnacles and the abundant
light due to the shallow depth allow a large variety of marine
life to thrive there. over 50 different species of fish and
marine mammals are said to inhabit the Cordell Bank.

I am also quite concerned that the Cordell Bank be given 1. See Generic Response B.
adequate protection from any future off-shore oil and gas
roduction. Many individuals and groups have expressed their 2. see Generic Response A.
esire to see Boundary Alternative #1 adopted to allow for
increased protection from pollutants and other hazards that
could drift into the sanctuary. I hope you will give their
concerns your full attention.

Thank you for your consideration in this matter.
q@al
ir
cc
C,

Sincerely,

PETE WILSON

PW:sa

UNITED STATES DEPARTMENT OF COMMERCE
Nations) Oceanic and Atmospheric Administration
September 16,1987 NATIONAL MARINE FISHERIES SERVICE

Ms. Vickie Allin, Acting Chief
Marine and Estuarine Management Division
National Ocean Service
NOAA
1825 Connecticut Avenue, N.W. Suite 714
Washington,D.C. 20235

Dear Ms. Allin,

First I want to thank you for the opportunity to review and
provide comment on the Draft Environmental Impact
Statement/Management Plan for the Cordell Bank National Marine
Sanctuary. As you may know my research colleagues and I at the
NMFS Tiburon Laboratory have been conducting research on the
rockfish (Sebastes spp.) populations in the Gulf of Farallons and
Cordell Bank for over three years. We have developed considerable
interest in the conditions of these populations and have found
the Cordell Bank to be a unique and valuable habitat. Your
efforts to protect the resources of this place through creation
of a National Marine Sanctuary are laudable.

It is not our usual duty to review documents such as this. So I
will not address technical aspects relating to adequacy,
suitability and such. I do, however, have some general and
specific comments from the perspective of a research fishery
biologist - the bias will be obvious.

General comments:

1. Most of your descriptive information on the Bank comes
from Bob Schnieder and his Cordell Bank Expedition. He and his
group have done a great job in compiling information and
creating a public awareness of Cordell Bank. Until a few years
ago they were the only people working there. I must confess that
I find it interesting that within our agency there is so little
communication between groups working in the same geographic area
and with the same interests. There is considerable information on
the oceanography and the groundfish populations (primarily
rockfishes)in the regions of concern which has been produced by
the NMFS Southwest Fisheries Center. For instance, the
Physiological Ecology Investigation of the Tiburon Laboratory has
been sampling the yellovtall rockfish population at Cordell on a
monthly basis for 2 1/2 years and seasonal research cruises have
explored this area for at least 8 years. In our particular work
we are studying the reproductive biology of yellowtail RF in
relation to their physiological condition. It appears from our
results that Cordell may very well be a unique habitat. There are
some conditions and disease states within the fish populations
which are unlike those in other Pacific coast populations. There
is a real need to coordinate the available scientific information
and the research activity of Cordell Bank rezearchers. Your

proposal could help meet this need. We would like to be included
in the process and the final organization that results from the 1. comment accepted. NoAA agrees with the importance of a coordinated research
creation of the sanctuary. I think we have a lot to contribute. effort and encourages the participation of the NMFS Tiburon Laboratory In the
2. Why is it necessary to create a new and seperate sanctuary for development of the Sanutuary's overall manager-t and -search programs.
Cordell when it borders on an existing sanctuary? It would seem
easier and logical to just add it to the Point Reyes-Farallon 2. The two sanctuaries each contain uniquely distributed resources that require
Islands National Marine Sanctuary. different types of regulation and protection. However the management
structure will be the same for both estuaries enabling a minimization of
3. One outcome of our research at Cordell that has impressed us additional resources to manage the new Cordell Bank National Marine Sanctuary.
is the complexity and uniqueness of the habitat and how little we
know about it. The estimated research budget of $65K per annum
seems inadequate to cover the range of research proposed. For
example, it costs us $1000/day to charter a vessel to collect
fish. When you consider subsequent lab work, salaries, etc. money
3 does not last long. 3. See Generic Comment G.
Specific Comments:

1. Enforcement is a problem at Cordell. Any proposed new
regulations concerning activities there will require some thought
and probably money to provide adequate enforcement. Both
California Dept. of Fish and Game and the Coast Guard have their
hands full now. 4. see Generic comment I. NOAA encourages and will supporty to the degree
possible fisheries research on Cordell Bank, including studies of commerically
2. Page 6. The statement about the lack of threat to fish at valuable fish stocks.
Al- @ordell may not be supportable. There are some preliminary
indications of overfishing in the rockfishes. No one is looking
at the potential problem but it warrants concern.
3. Page 23. Here are some additions to your list of Cordell Bank 5. These additions have been made In the FEIS/MP.
fishes: Greenspot rockfish, Sebastes rosenblatti
Greenstripe rockfish, 6_. chlorostictus
Chilipepper rockfish, $_ goodei
Rock sole, Levidopsetta bilineata 6. This correction has been made in the FEIS/MP.
Spiny dogfish, Scrualus acanthias.
4. Page 24. Lingcod spawning season is usually late fall through 7. 'ihis correction has been made in the FEIs/MP.
early winter. 8. 'Ihis text has been added to the FEIS/MP.
-7 5. Page 24. Yellowtail rockfish do not prey on jack mackerel. 9. rfhe proposed regulations do not prohibit any activity conducted by the
6. Page 29. There is some text missing from the bottom of the Department of Defense (EOD) that is essential for national defense or because
page. of emergency. Such activities shall be conducted consistently with the
Sanctuary regulations to the maximum extent practicable. NOAA has no
1
7. Page 42. Perhaps I am naive, but it seems the military should information to indicate that military operations, as currently conducted in
not be exempt from any discharge or developmental requirements in Sanctuary waters in3ure its resources. However, NOAA shall continue to
this area unless they can demonstrate in public how Cordell is consult with the D0D to maintain awareness of military operations in Sanctuary
necessary for national defense. waters and to inform the military of sensitive marine habitats. NOAA will
closely monitor all activities and increase the public's as well as D0D1s
B. A table listing acronyms would help. It is almost another form awareness of the need to protect the resources of the Sanctuary.
10 of language. 10. A table of acronyms has been added to the FEIS/MP.
9. Page 53. For possible distribution points. for information to
the public the UC Bodega Marine Laboratory has been selected for

a new site for the NMFS Tiburon Laboratory. If(when?) this takes
placeI one might give it a consideration since the mission of 11. One of the main purposes of Sanctuary Designation is to enhance public
this lab is to study groundfishes along this coast. awareness and appreciation of the marine environment. NQAA will consider the
10. Page 84. From years of research in oil pollution effects I University of Califorina's Bodega Marine Laboratory as a possible location
concluded long-term chronic exposures were much more threatening for public Contact to achieve the goal of increasing public awareness and
to a marine community than the occasional, and often rare, understanding the significance of the Sarctuary and the need to protect its
catastrophic spill. One might want to consider potential threats resources.
of such exposures ahead of spills. Nearby shipping activity,
exploratory drilling, mineral development, and a proposal for 12. See Generic Responses H, B, and C. NOAA fully recognizes the threat of long
placement of a major municipal sewage outfall at Bodega serve as term chronic exposure to low levels of pollution and intends to intitiate a
examples. Program to monitor the status of the Sanctuary's resources.

I hope these comments are of use to you and your efforts. Please
keep us informed of this proposal. We wish to cooperate wherever
possible.

Sincerely

Maxwel
Superv. Fish. Biol.
NMFS- Tiburon Lab.
3150 Paradise Dr.
Tiburon, CA 94920

cc: Mr. Edward Wilczynski, Acting Chief
Ecology & Conservation Division
National Ocean Service, NOAA
U.S. Department of Commerce, Pm. 6814
14th & Pennsylvania Avenues
Washington, D.C. 20230

UNITED STATES DEPARTMENT OF COMMERCE
National Oceanic and Atmospheric Administration
NATIONAL MARINE FISHERIES SERVICE

Southwest Fisheries Center
P.O. Box 271
La Jolla, California 92038

September 28, 1987 F/SWC1

Ms. Vickie Allin
Acting Chief,
Marine and Estuarine Management Division
Office of Ocean and Coastal Resources Management
National Ocean Service/NOAA
1825 Connecticut Avenue, N.W.
Washington, D.C. 20235

Dear Ms. Allin:

I have reviewed the draft environment impact statement/draft
maanagement plan sent for the proposed Cordell Bank National
Marine Sanctuary. I found the plan to be sound and I. See Generic Response A.
comprehensive, the major considerations well accounted for, and
he Cordel 1 Bank area to be a good candidate for a National
arine Sanctuary. I support the described preferred boundary of
he Sanctuary (Alternative 2), as well as the preferred
lmmtt anagement and regulatory alternatives.
If you have further questions, don't hesitate to let me know.

Sincerely,
luo, I A J-

Aleta A. Hohn, Leader
Life History Monitoring Project

cc: E. Wilczynski

OUR IGO

UNITED STATES DEPARTMENT OF COMMERCE
National Oceanic arid Atmospheric Administration
NATIONAL MARINE FISHERIES SERVICE
Southwest Region
300 South Ferry Street
Terminal Island, California 90731

October 6, 1987 F/SWR33:SJK

MEMORANDUM FOR: N/ORM2 Vickie Allin
FROM: F/SWR E. C. Fuil@g @_o

SUBJECT: Draft Environmental Impact Statement/Management
Plan, Cordell Bank National Marine Sanctuary

We have reviewed the subject document (DEIS/MP) and do not find
the preferred regulatory alternative to be acceptable as proposed.

As discussed in the document, Cordell Bank supports a unique
ecosystem with an abundance of organisms including some rare and
previously unknown varieties. Marine mammals, including
endangered whales, also are observed in waters over and adjacent
to the Bank. We, therefore, concur that Cordell Bank warrants
designation as a National Marine Sanctuary.

Upon designating Cordell Bank a National Marine Sanctuary, the
Management Plan should ensure the protection of biological
resources found there. Unfortunately, the draft plan proposed in
the DEIS/MP falls short of providing such protection in several
ways.

First, there is the lack of restrictions on hydrocarbon
development activities within the sanctuary. Such restrictions
are in place for the Point Reyes-Farallon Islands National Marine
Sanctuary (PRNMS) located immediately south of Cordell Bank. The
vague intent to promulgate regulations, or possibly to prohibit
such operations in the future does not ensure that such
restrictions would be developed and enforced. As presently
d
pecified in the DEIS/MP, it appears that the fate of potential
oil and gas activities within the proposed sanctuary lies
primarily with the U.S. Department of the Interior's future
ecisions on whether or not to offer the area for leasing.
Because of these concerns, we do not support the preferred see Generic Response B.
regulatory alternative for hydrocarbon activities, Alternative
C3(a), described on page 74 and elsewhere in the document. We do
not think that oil and gas operations should be allowed within
the proposed sanctuary because of potential adverse impacts on
the biological resources of the Bank. However, we would support,
and do encourage the adoption of Alternative C3(b) provided it is
amended to reflect the change, 11 ... a regulation would be
promulgated prohibiting oil and gas development within the
sanctuary boundaries." Also, the monitoring concept discussed

probably should be eliminated unless it is determined that the
Marine Protection, Research and Sanctuaries Act can require
monitoring of oil and gas activities occurring outside the
boundaries of a designated sanctuary.
Second, we find the provisions for enforcing sanctuary
regulations for the protection of marine resources to be vague,
if not lacking. There is no provision for an enforcement officer
as presently exists for the PRNMS. Rather, under this plan,
enforcement of regulations for protecting these resources would 2. See Generic Response G.
be left to other agencies as an additional item under their broad
responsibility for enforcing Federal and State laws. This plan
would not provide sufficient protection of resources, and we
believe that an enforcement plan such as that for the PRNMS, with
well described authorities and functions, should be formulated
and implemented.
Third, we *think that the proposed Cordell Bank Sanctuary should
consist of all the area contained within Boundary Alternative 1,
described on pages 64 and 65. This boundary would join that of
the PRNMS, establishing a single large area, which could be
managed as a unit. This would allow for better management and 3. see Generic Response A.
better enforcement of sanctuary regulations, since one large unit
would have more easily definable and enforceable boundaries. In
addition, this would assure a protected buffer zone between
Cordell Bank and the PRNMS and also provide additional protection
for marine mammals that frequent the entire area, not only the
area within the proposed sanctuary boundary (Boundary Alternative
2).
Finally, the proposed Management Plan specifies that removing or
damaging benthic organisms within the proposed sanctuary, except
for research or educational purposes, would be prohibited. The
plan should clearly acknowledge that commercial and recreational 4. See Generic Responses E and I.
fishing will be activities excluded from the scope of such
sanctuary regulations, and will continue to be administered under
existing State and Federal authorities. This is consistent with
the management regime established for the Point Reyes - Farallons
Sanctuary.

If there are questions regarding these comments, please contact
Sari Kiraly of my staff, at the National Marine Fisheries
Service, 777 Sonoma Avenue, Room 325, Santa Rosa, California
95404; telephone (707) 525-4275.

cc:
F/PR - Nancy Foster

3 VL/3

7, q
1. nus correction has been made in the FEIS/W.

U.S. DEPARTMENT OF COMMERCE

F@: o

AJ
re (@f I L

1. No Paspmse Neoess-y.

kc,
LIOD,

United States Department of the Interior

OFFICE OF THE SECRETARY
WASHINGTON, D.C. 20240
In Reply Refer To: OCT 187
ER-87/1066

Vickie R. Allin
Acting Chief, Marine and Estuarine Management Division
Office of Ocean and Coastal Resource Management
National Ocean Service
National Oceanic and Atmospheric Administration
1825 Connecticut Ave., N.W.
Washington, D.C. 20235

Dear Ms. AWn:

The Department of the Interior has reviewed the proposed Cordell Bank National Marine
Sanctuary regulations (published in the Federal Re ter on August 28, 1987), and the
t
supporting draft environmental impact statemen WIS . Our specific comments
(enclosed) are divided into two parts: Comments on the proposed rules; and comments on
the draft EIS. General comments follow.

Overall, Interior supports the concept of establishing a marine sanctuary at Cordell 1. The diverse and abundant resources at Cordell Bank warrant an areal system of
Bank. The Bank area contains important ecological, research, and recreational values protaction provided by designation as a National Maririe Sanctuary. NOAA does
that warrant protection from certain unregulated activities which may adversely affect riot intend to add unnecessary regulations or layers of authority to the
its resources. However, designation of Cordell Bank as a national marine sanctuary management of the Cordell Bank ecosystem. The added protection is intended to
should not be used as a mechanism for developing regulatory programs that duplicate any fill the gaps between existing laws and to provide a coordinated program of
of those currently in effect. on-site management.

e acknowledge that the National Oceanic and Atmospheric Administration (NOAA) is 2. NaAA does not intend to regulate any oil and gas activities at the time of
not planning to address offshore oil and gas development activities in the sanctuary deSIgnation. NQAA also agrees that there are many regulatory medmnisms,
regulations. However, the proposed rule does indicate that hydrocarbon-related some administered by the Departnerrt of the Interior, to protect the marine
regulations may be considered in the future. It will not be necessary or appropriate for environment. Also Generic Response B.
NOAA to place restrictions on oil and gas activities authorized by Interior because we
already have mechanisms in place for ensuring that resources of Cordell Bank will be
adequately protected from potential adverse impacts caused by those activities.
Thank you for the opportunity to comment on the proposed regulations and the draft EIS.

Sincerely,

1
" poo
Martin L. Sm th
Deputy Assistant Secretary,
Policy, Budget and Administration
OCT BIS;

Enclosure
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Enclosure

Detailed Comments on Proposed Re lations and
Draft Environmental Impact Statement(EIZU/management Plan
for the Cordell Bank National Marine Sanctuary (NMS)

COMMENTS ON PROPOSED REGULATIONS

1. General comment on applicability and coverage of the regulations.

As written, it is unclear whether the regulations would apply only within the 50 frn
.obath, and which user groups they would apply to. For example, it must be 3. See Generic Response E.
clarified whether hydrocarbon development regulations that may be developed in
the future would apply outside the 50 fm isobath but within the 3 nm preferred
sanctuary boundary. We believe it is appropriate to apply the rules to an user
groups, but limit the scope to areas within the 50 fm isobath. Both issues need to
be clarified.

2. Section 942.6(a)(1). Depositing or discharging materials or substances.

With the exception of solid wastes, vessel discharges of "materials or substances"
(e.g., oil or other toxic substances) are covered by existing laws and regulations.
Therefore, it will be unnecessary to I'layer" additional regulations onto the existing
ones. If unregulated discharges are to be addressed, they should be specifically 4. See Generic Response F.
identified. For example, disposal of "nonbiodegradable" materials should be one
focus of the regulations. Further, the regulations should take into consideration the
accidental and unavoidable discharge of material such as fishing gear. It would be
appropriate to limit this regulation to "deliberate" disposal of prohibited materials.

3. Section 942.6(aX2). Removing or damaging resources.

In most cases the draft EIS indicates that this regulation would provide for the
prohibition of "deliberate" removal or damage to "benthic resources." However, the
proposed regulation is unclear as to what constitutes "deliberate" and what is
included as a "benthic resource." The rule should be clarified to address the
following questions: 1) Does deliberate removal exclude accidental situations in
which the commercial trawler hangs up on or drags the bottom? 2) Does deliberate
damage exclude damage due to a dropped or dragging anchor? 3) Do benthic
sources include only aLgae and invertebrate species (i.e., are an fishes including
those not specifically covered by the Fishery Management Plan exempt from the
regulation)?
With respect to fishing, it is a known and predictable fact that damage will occur to 5. S- Generic Responses 1, E and D.
"benthic resources," and some benthic resources not regulated by the Fisheries
Management Plan will be captured incidentally, given the nature of some fishing
activities. While there are indications that fishing, per se, will be subject only to
existing regulations and not be further addressed in Article 4 of the sanctuary
designation document, it is unclear how activities related to fishing or fishing
vessels will be affected by the regulations, particularly as they apply to anchoring,
trawling, and incidental catch.

-2-

With respect to the "attempting to remove or removing" provision, it appears to be
a 'blanket" and nonspecific prohibition directly aimed at divers who might remove
Allopora for commercial use. However, the terminology used is vague and includes
all benthic organisms. As a result, many activities including commercial fishing
and pleasure boating may be affected by the proposed regulations due to the nature
of the activities. Finally, if non-diving activities are to be covered, the regulation
should include a provision to ensure protection of the benthic organisms from
damages caused by anchoring.

Considering the number of potential diving days on the Bank and the limited bottom
time of divers, it is difficult to understand how divers would pose a significant
threat to benthic resources other than Allo2ora. If the intent of the regulation is
full protection of Allopora it should specify this resource, while not categorically.
excluding "other" resources.

COMMENT'S ON THE DRAFT EIS AND MANAGEMENT PLAN.

1. Lack of emphasis:

It appears that "strengths" and "highly significant" aspects of the Bank have been
underrated or have not been emphasized. In particular, stronger statements may be 6. comment accepted. NQAA agrees that there is a lack of information concerning
necessary to justify the proposed designation action. There are numerous factors the "highlights" of the Sanctuary resources. Although Cordell Bank is an area
that could be highlighted particularly under the heading of "Purpose and Need for of exceptional @Iogical value it has only recently been "discovered" through
Designation." These "highlights" may include: the efforts of a few researchers whose investgations have assisted NOAA
recognize Cordell Bank's national significance.
a. The unusual combination of oceanic conditions and undersea
topography represented within the confines of the proposed Cordell Unfortunately there is still very little known about the general
Bank NMS. These unusual conditions of high productivity and oceanographic regime around Cordell Bank and less about the specific details
presence of a variety of microhabitats have lead to an unusually of microhabitats and species diversity. A number of reports are available
diverse community; that describe seamounts and submerged coastal banks in general but no simlar
b. Habitat and foraging areas for a variety of commercially and/or studies have been dom on Cordell Bank specifically.
recreationally important fishes; The research divers, mentioned above, have managed to do an excellent job
in ccapiling the original baseline data. These data have enabled us to gain
C. The utilization of Cordell Bank as a foraging area for marine our first ruclimentary understanding of the Bank's structure and function.
mammals and seabirds which may concurrently utilize the varied They have ccapiled detailed lists of invertebrate and benthic organisms as
habitats of nearby Point Reyes-Farallon Island NMS for additional well as empleted surveys of local topography and geological diversity. In
(nesting) or similar (feeding) activities; addition, NQAA has funded aerial and at-sea surveys of marine mammal abundance
and distribution while the local NMFS and CDF&G laboratories have investigated
d. An important and significant habitat for new, rare, and/or endangered the local fish population dynamics.
species; and NOAA is aware of the gaps in our urderstanding of the ecology of Cordell
e. Cordell Bank would provide a relatively pristine site in which to Bank and intends on designing a research plan and monitoring program to
initiate research studies and/or act as a control site to complement further investigate the special resources within the Sanctuary.
other research studies. Sanctuary designation would assure an
organized funding plan for this unique area.

-3-

2. Socioeconomic Impacts. 7. This addition has been made to the FEIS/MP (Part IV, Section II). In
fact it is possible that Sanctuary designation will sti=late the local
The draft EIS needs to adaress the possible socioeconomic impacts of the proposed econoury in t*xms of increased visitation and public awareness. It is unlikely
7 action on various user groups including "excursion" services used for whale watching that the increased unsage will negatively impact the Bank Is resources. NOAA
or nature viewing. If socioeconomic impacts due to the proposed action are will monitor these activities to detexmine any effects of increased usage.
negligible, it should be stated.

3. Environmental Conditions (page 17).

A complete description of environmental conditions should include specific and
cited information regarding currents, water chemistry, upwelling, nutrient levels,
productivity, chlorophyll measures, etc., if available.
4. Tables and Figures. 8. 1his technical information has been incorporated when available.
In general, the document would benefit from the inclusion of additional tables
and/or figures that summarize or illustrate the following:

a. Partial List of hivertebrates and Algae;

b. Changes in Species Assemblages with Depth;

C. List for Newly Discovered, Rare, Endangered and Threatened Species;

d. Distributions of Marine Mammals and Seabirds;

e. Commercial Fishing Activity at Cordell Bank (including map of
Ci locations by gear type and species);
f. Summary Table of Proposed Action and Boundary, Management, and 9. r1he summary of proposed boundaries has been presented in Figures 5 and 6.
Regulatory Alternatives; and Management and regulatory alternatives do not change between bouux1ary
g. Anticipated Timetables for Management Plan Reviews, Sanctuary alternatives therefore these statements have been left in the original text
10 Research Plans, etc. format.

5. Short-tailed albatross: 10. See Generic Response G. Final and detailed timetables will be
formulated using the local expertise, after the Sanctuary has been
The short-tailed albatross is mentioned as endangered on page 6 and again on page designated. Management Plan Reviews take between 3 to 5 years whereas
62; yet it is not considered in Part 11, Section II.B.2(d), Seabirds. Since the species Sanctuary Research Plans are prepared annually.
is listed as endangered, it is an important and significant component of the fauna at
Cordell Bank and deserves discussion. Information regarding when the species was 11. This information has been arlied to the FEIS/NP.
sighted and by whom should be provided.

6. References to "Plants." 12. aliese corrections have been made in the FEIS/MP.

Replace the word "plants" by the more appropriate and specific term "algae". (See
page 19, last paragraph; page 21, line 6.)

-4-

7. Abbreviations. 13. It is No;,Ass experience that california Fish and Ga- is More camionlY
13 California Department of Fish and Game (CDF&G) is more widely abbreviated as referred to, and abbreviated as, CF&G.
CDF&G rather than as CF&G as used throughout the document.
It would be useful to include a table of acronyms in the document. 14. This table has been added to the FEIS/MP.
8. Citations.

There are numerous examples throughout the text where factual data have been
presented but are uncited. To increase the scientific validity and defensibility of
the draft EIS, statements of fact should be properly cited. Citations should be used
particularly in support of statements made on the following pages:

Page 17. Geology (paragraphs I and 2);

Page 18. Metereology;
Page 18. Waves and Currents; 15. These citations have been added wherever possible in the FEIS/MP.

Page 22. Fin Fish (paragraph 1); and

Page 77. Oil Spill Impacts on Seabirds.
9. Maps. 16. All maps in the FEIS/MP have been corrected to imlUde
latitude/longtitude lines.
All maps should have latitude/longitude lines.

10. Metric/Standard Equivalents.

While adequate in most cases, it is appropriate that all standard measures be
accompanied by their equivalents. See the following pages.
17 Page 19. (degrees F and degrees C): 65 feet (? in); 100 feet (? in);

Page 28. 300 foot 0 in or ? fathoms);
Page 29. 300 foot (? in or ? fathoms); and 17. These reasurement conversions have been added to the FEIS/MP.

Page 51. 115 feet (? in)

PAGE-BY-PAGE COMMENTS

Page iv, Part IV, Section I.A.I. Retitle "Regulatory and Enforcement Regime" to
read "Resource Protection Regime" to match the heading in the text (page 75). 18. This correction has been done in the FIES.
191 Page 4, bullet 2 Update the information on the Fagatele Sanctuary. 19. This addition has been node in the FEIS/MP.

=@@rga "Assortment of bentbic organisms is exceptional due to its
ti. tidal and subtidal species." The implication that "intertidal"
species coexist with subtidal species is misleading in that the use of the word
2-0 "intertidal" in this context may serve to imply that the Bank is periodically covered 20. The FEISIMP bas been modified to remove the inconsistency.
and uncovered by the tides. The draft EIS should be consistent in using the phrase
"combination of nearshore (subtidal) and offshore (oceanic) species" (as on pages xi
and 102).
Page 5, paragraph 3. Avoid the use of undefined characterizations (eg., 21. This has been oorrected in the FEIS/Mp.
"extraordinarily lush and healthy") when discussing the biology of the Bank.
-Z Z. Pj@. 6 ' h 6-7. Replace "on nine of sixteen" with "nine times over the course of
s teen". 7Ss. comment below regarding pages 26-32 for further clarification.) 22. This has been corrected in the ms/mp.

Page 6, paragraphs 2 and 3 While increased boat traffic and unrestricted diving
are termed I'less serious," they are in all probability "negligible" sources of impacts
since the Bank is relatively inaccessible during most times of the year. Particularly
in regards to the "diver" impacts, it appears that an underlying concern here is 23. NQAA is concerned with the protection of all resources. It is not NOAA-s
toward safeguarding Alloeora. The concern for this rare coral is acknowledged, but intent to Only protect A119P9 but all berithic resairces. Clarification and
suggest that this subject (i.e., Allopora protection) be dealt with specifically rather exceptions to this regulation have been incorporated into the FEIS/MP (See
than blanketing this by vague Fe-gulation. other than removal of Allopora it is Generic Responses D and I).
unlikely that there would be significant impacts from removal of benthic resources
by sport divers. 24. This has been corrected in the FEIS/Mp.
Page 12, paragraph 2 Add the word "wide" following the phrase 4.5 miles." It
Vt would also be appropriate to explain here why the alternative is preferred.

Page 12, paragraph 3 "There is no offshore.... north of the Bank". This sentence
in unsupported and unsubstantiated. There are several, if not many, rocky features 25. This bas been corrected in the FEIS/MP.
north of the Bank. This statement could be written as, "To the north, there is no
offshore, shallow-water area with physical features similar to the Bank."
Page 15, FVre 3. This figure depicts the bathymetry of the Bank proper, but does
n.tin,
.Jude the bathymetry of the preferred boundaries of the sanctuary. The
reference to the figure in the text should be changed to reflect the actual
:Z6 boundaries of the figure, or vice versa; the bathymetry map should be expanded to
include the boundaries of the sanctuary. 26. This Figure has been deleted from the FEIS/Mp.
Also, provide a depth designation of the feature in the mid-left or western side of
the figure.

Page 16, paragraph 3, "California Current flows southward along the coast bringing
nutrients to the qrlevels of the nt@ while the u welling of nutrient-rich,
- up 1 _T_
Ueep-ocean waters t ulates the g:t 0 p .kton S. High levels of
productivity on the Bank are indeed due to upweUing LC OM
PEI and water
clarity. However, it is not clear that the California Current is an additional source
of nutrients. Typically, surface currents like the California Current are very low in 27. This has been oorrected in the FEIS/MP.
27 nutrients. Do productivity data exist to support this statement? If not, it is
sufficient to explain nutrient enrichment on the basis of upwelling alone, and it is
not necessary to include the California Current as a nutrient source. Similar
references to this were made on p. 18, last line; p. 19, para 2; and p. 20, line 1.

2 ER I Page 17, line I "algaes" should read "algael.. 28. This has been corrected in the ms/mp.
Only the geology of the Bank proper is described (i.e., hard
M"i.".01r2egs), since tne preferred boundary includes up to 3 nautical miles 29. The description of the bottom features around Cordell Bank and within the
around these features, bottom features surrounding the bank should be included in sarcbkirY has be- added to the FEIS/MP. For further information see the
the geologic description (i.e., description of soft bottom). management Plaii for the Point Reyes-Farallon Islands Natiorka marine
Page 19 Line 2 should read: "the Coriolis effect, it is replaced by deep, nutrient- Sanctuary-
rich waters moving upward to the surface." 30. This has been corrected in the FEIS/MP.
Page 19. lal Yom - This is a rather confusing explanation of trophic
relationships td thio,=mTshe first line of this section would better read, "the
highlight penetration and nutrient influx to Cordell Bank waters provides an
environment suitable for rich growth of phytoplankton and macroalgae. These
Igae, in turn, support a variety of organisms on several trophic levels." While it is
true that the "bulk of the biomass" will be red algae at any given time, if the
31 a em is dominated by filter feeders (as indicated on page 20), then the ecosystem
syst
is more likely to dependent upon energy contributions from abundant 31- CMMent accepted. Ibis has been corrected in the FEis/MP.
pbytoplankton. There are indications that "plankton" studies must have occurred
since the rare and unusual diatom "Ento I " is mentioned in the Federal Register
Notice of August 25, 1981. These types 07 ta should be incorporated into the EIS.

The section is extremely vague in regard to which species are found at Cordell
Bank. For example, what are "other types" of algae, and what other inverts besides 32. A table of representative invertebrates, algae and plankton has been added to
*3 ZI rare species inhabit the Bank? A table of representative algal, planktonic (where the FEIS/MP.
available), and invertebrate species should be provided.

Insert the phrase "together with a diverse and heterogeneous substrate" between
131 words "waters" and supports" on page 20, line 2. 33. 1his has been corrected in the MS/Mp.
Summarize rare forms and species extensions by geographic range or depth in a 34. Rare forms of species are included in the species lists in the tables in the
3+1 table. t-t- Detailed descr'Pti- by ge0graPh-1c range or depth distribution are
unavailable at this time. Future research efforts will investigate these gaps
An additional reason that Allopora may be found in large numbers is possibly in Our knowledge of the species distxibutions.
351 because of low collection pressure. 35. This addition has been made in the FEIS/Mp.
In the Federal Register Notice of August 25, 1981, three species were listed as new
discoveries and another listed as rare or unusual. Three of these four species are
not included in the draft EIS. Since these species likely represent "unusual" and 36. These species have been aciam to the ms/tT speci,, lists.
36 significant aspects of the Cordell Bank resources, they should be included.
Page 20, paragraph 3. "Ecotocarpales" should read "Ectocarpales.11 It should not be 37. These corrections have been made in the ms/mp.
underlined or italicized as it refers to taxonomic order. Corallinaceae refers to a
37 family and should not be underlined, either.
nP:ge lltparkrapther@. By definition, if an organism also occurs subtidally, it could
be'.. 'ic intertidal.11 An example of such an organism(s) would clarify what
3 is meant. 38. This has been corrected in the FEIS/Mp.

-7-

If biological zonation is such an important and significant feature 39. Rare forms of species are inclikied in the species lists in the tables in the
391 -,pagfi@,F-' a figure illustrating the pattern would be appropriate. Portrayal text. Detailed descriptions by geographic range or depth distribution are
of changes in assemblages by depth in a table or general outline would increase the unavailable at this time. Future research efforts will investigate these gaps
clarity of the presentation and act as a "quick reference" for referrals within the in our knowledge of the species distributions.
text.
+01 Pgie 2g2
tin That "competition for space becomes the major population 40. This has been corrected in the FEIS/MP.
.C
t.r
11 is a supposition and has not been experimentally determined.
p
ragra 2 "Th a o bination of . . . found in few, if any, other
imins phtIe . e p rticu", * Z
al te h ords N? nyr"L attempt should be made to correlate and 41. This has been corrected in the FEIS/MP.
compare Cordell Bank phenomena to studies of other banks. For example,
comparison of the biological assemblages with Tanner and Cortes Banks would be
pertinent since these banks are similar to Cordell Bank in their construction,
surrounding oceanographic conditions, and occurrence of Allopora populations.
Page 22. (b) Change the heading 11(b)" to either "Fish Resources" or "Fishes" since 42. This has been corrected in the FEIS/MP.
not all species listed in Table I are fin fishes and it would be unrealistic and
inadequate to cover only that group of fishes.
@T22 M Ig Fish. Table I in reality lists 38 species of fish that have been
i@d by' hmieder, 1985, in waters of Cordell Bank proper and is not
representative of all fishes to be found within the confines of the preferred
boundary of the sanctuary (particularly demersal species living over sand). The
CDF&G commercial catch records (for both trawl and nontrawl gear methods)
would help identify which additional species are likely to occur.

Table 1. Consult additional and current sources to generate a more complete and
up-to-date list of fishes within the preferred sanctuary boundaries. For example,
1977 CDF&G commercial catch data from fish blocks inclusive of the Bank indicate
the presence of chinook and coho salmon; English, rex, and Dover soles; California 43. These corrections arid additious to Table I have been made where the
halibut; thornyhead; splitnose rockfish; and Pacific ocean perch. information is available.

Table 1. "Vermillion" rockfish should read "Vermilion" rockfish.

Table 1: It is surprising to find that "kelp bass" are not included in the table as they
are indicated as present in both Federal Register Notices and several popular
articles written by Schmieder.

Avoid nonscientific descriptions whenever possible in discussing the biology of he
Bank; for example, "blue rockfish and several red varieties are especially colorful 44. The language of the DEIS/MP is riot only neent for strict scientific
as they swim around the ridges and slopes." What should be emphasized is that the interpretation. in addition the descriptions of the rockfish emphasizes the,
unusual topography of the bank provides for a variety of habitats which may contrasting variety of fish species and the unusual clarity of the water at
account for the tremendous diversity of fishes, in general, and rockfisnes the associated depths.
specifically.

It would be appropriate to defer specific discussion of sportfishing data to the
human activities section later in the draft EIS. 45. This has been corrected in the FEIS/MP.

46. This has been corTected in the FEIS/MP.
It is not appropriate to assume that the number and types of fishes caught by 47. These citations have been added wherever necessary.
sportfishermen necessarily reflect of the relative abundance of all fishes inhabiting
the Bank. The types and numbers of fishes caught and reported by sportfishermen
are functions of gear used, desirability of the species, and size and ease of 48. The corrections have been made in the FEIS/MP. It is not our intent to give
capture. For example, small but abundant benthic fishes will be underestimated. detailed fi4Le_ry statistics but to highlight the overall patterns of human use
The source(s) of factual data regarding age/size/life history of fishes discussed in in the Sanctuary area.
+71 this section need to be cited. 49. As the text explains the gray whale is known to pass through the area but was
riot observed on Cordell Batik by Webber and Coopex and therefore riot added to
Table 2. The average annual catch data for each month for major species should be data in Table 3.
presented rather than the sum over an arbitrary unit of time (I I years). Also, a
discussion of any trends apparent from this data in the text (i.e. is there a pattern 50. This has been corrected in the FEIS/MP.
through time?) should be presented. Tables shoulo be checked for accuracy. For
example, in Table 2, the sums of numbers in columns 6, 7, 8, 9, and 10 should equal 51. The text clearly explains that the number of sightings is different from the
number presented in column 2 but do not. Finally, more recent data (post 1981) frequency of occurrence. It is only our intent to give the reviewer a
should be available and incorporated into the table. description of the species types and abundance in the Sanctuary.
Pages 26-32 Marine Mammals and Seabirds. The text indicates that 14 species of 52. This information is available in the text.
mammals have been sighted, while Table 3 indicates only 13. Table 3 may be better
entitled "Marine Mammals Observed on Cordell Batik During the Webber and Cooper 53. See Generic Response A. It was our intention in the DEIS/MP to outline the
Study 1981 and 1982." value of all living resources in the vicinity of Cordell Bank. The species
and patte.@i@ of fish, benthic organisms and sea birds, (as well as whales),
The text indicates that 373 sightings were made during 16 total cruises. This is not were described so that a reviewer of the DEIS/MP would gain a perspective of
Sol consistent with data presented in Table 3 in which the total number of sightings the biological diversity and abundance of all natural resources on the bank.
adds up to 267.
Marine mammals are a significant resource and NoAA recognizes the
The number of sightings should not be confused with frequency of occurrence. For importance of detailed investigations into their abundance, distribution and
5.1 example, 9 sightings out of 16 cruises is not the same as a species being seen on 9 behavior. Cordell Bmik is especially important in this regard as a habitat
separate cruises out of 16 total cruises, since all 9 sightings may have been made on for marine mammals. NOAA is aware of the numerous sightings of marine
a single cruise. It would be informative to include a frequency of occurrence value mammals in this area and how their abundance changes both annually and
in Table 3 with the latter type of data, i.e., on how many of the cruises were seasonally. Hadever, many questions remain regarding individual behavior
particular species actually observed. patterns and fire scale distribution patterns around Cordell Bank. NOAA,
through the Point Reyes-Farallon Islands National Marine Sanctuary, has
Table 3. Clearly indicate in the table the dates of the survey and the level of SU14-rted research over the past three years to investigate the distribution
52 1 effort. and abundance of humpback and blue whales as well as opportunistic sightings
of other marine mammals. Aerial and vessel-based survey methods were able to
The "areul;,distribution of seabirds and marine mammal feeding grounds should be identify individual humpback whales. This research has provided a thorough
5-3 put into a gure. This is especially important in as much as it represents the only baseline characterization and suggests that a local, "resident" population of
rationale provided for the 3 nautical mile preferred boundary. 88 humpback whales exist's in the Point Reyes-Farallom-as National Marine
Page 28, paragrap " "Pac 'i white-sided dolphins - ,were Sarict:uary and adjacent region.
U.,=Justtothe
northwestiv. 'JusP@httld be IcIplaced by an appr e of distance. 54. Ibis has been corrected in the FEIS/MP.
55 Page 29, last line The final sentence on this page is incomplete. 55. This has bearl corrected in the FEIS/MP.
56 Page 30, paragraph 3 "juvenille" should read "juvenile". 56. This has been corrected in the ms/mp.

57. The corrections have been made in the
detailed fishery statistics but to high
Page 32. Human Activities Section. Treatment of commercial fishing activities in in the Sanctuary area. Also see Geneqxqic
the Cordell Bank vicinity is inadequate. While commercial fishing was described as NOAA agrees that there is a lack o
"significant" (page xi), "important" (page 51), and the dominant human activity at "highlight," of the Sanqfqtuary resources
the Bank (page 6, 32), no data were provided to support these assertions. It is exceptional ecological value it has oqn6q@
unnecessary to assume that "commercial catch is similarly dominated by rockfish" the efforts of a few researchers whose
(page 33) when data are available to support this statement and to clarify what recognize Cordell Bank's national signi
57 other species may be important to the industry. Consult CDF&G records and maps
for types of fishing activities, species captured, and gear used by commercial Unfortq-tely there is still very
fishermen working the area. This information could then be utilized in the analysis oceanographic regime around Oordell Bard
it impacts particularly as they relate to proposed regulations. Also, careful of micrchabitats and species divexsity.
consideration should be given to effects of various gear types on fish resources. that describe seamounts and submerged
While prohibition of gill netting has helped to preserve rockfish stocks, trawling for studies have been done on Cordell Bank
the same group may come into conflict with the proposed prohibition against
deliberate damage or removal of benthic resources (see comments above). The research divers, mentioned aqIxqA
in oqmpiling the original baseline data.
Descriptions of commercially and recreationally important species consider only our first rudimentary understardIng of
those species within the Bank proper. Once again, activities q(aspecial)y commercial They have canipiled detailed lists of
fisheries) related to species within the entire preferred boundary of the proposed well as ocapleted surveys of local
sanctuary should be described. addition, NOqM has funded aerial and
The human a tivities section should also include a description of existing facilities and distribution while the local NmFs ar
C the local fish population dynamics.
that provide "excursion" services for the purpose of "whale watching" or nature
viewing. The number of operators involved, their ports of origin, and average NqMA is aware of the gaps in our
number of trips per year should be cited. These data could then be used in the Bank and intends on designing a research
analysis of possible economic impacts- related to the actions. further investigate the special resource
qpq;2qg 332qgq,,2qg0qgaph 2 Change "February 1981" to "April 198111 and change "revised 58. See response abave.
Pose @. to "final" notice.
qP 59. 1his information has been added wherever
q@4 I sentence. Should state how far away the
.q1 3q@8q@ Ship 0q0 '
r C, Mt. a t Of hi.'q@Iqj, qOnt. 60. This has been corrected in the FFISq/Mp.
Page 37, line 8. it is unclear how data taken during a hydrographic cruise produced 61. The VISS is outside of the Sanctuary
2q2. detailed plots of 'biological communities." If these detailed plots exist, they should illustrates the location of the VISS and
be incorporated into the EIS.
62- ahe descriptions of species identified o
Page 41, paragraph I A complete and concise summary of the Designation the species lists in the FEIS/Mp.
Document should be provided as part of the paragraph so that the reader can
determine if it is necessary to turn to the Appendix to study the document in detail. 63. The qMIS/MP adequately summarizes the
throughout the text. A detailed summary
first sentence. This statement could be made I)EIS/MP who needs further detail of the
2qf2qf to consult the text found in Appendix 1.
68qq- Me',.- bqyq'qsqi2qmpsqeqf iq57'-'h2qmhb-qr 0q:,disenarges from entering the sanctuary. As presently
written, it is unclear who has the burden of proof of determining it sanctuary
resources are injured. 64. This has been corrected in the FEIS/Mp.
Page 42q.q(cq). We recommend that the phrase "no activity" be clarified (See also 65. This has been clarified in the FEISq/Mpq.
2qC2q5q1 page -7-3qTq-1t is neither necessary nor practical to exclude seismic survey activities has been, removed. Also, -,;Pp Generic
from the 50 fm isobath area.

66. NOAA agrees partially with this ccomerit, arid therefore has defined the scope
Page 42, last lin 1@severe impacts" if they did occur, would probably be of potential regulation of hydrocarbon activities to include the vAjole
Sanctuary. However the potential impacts of spillls and regular discharges
specifically limited to marine mammals and birds rather than to general "resources" associated with such operations, an the Bank itself, cannot be minimzed.
as written.
A major EPA study (EPA 440/4-85/002, &xgust 1985) described how different
a- -nt. Unless the phrase "and present severe health and safety hazards" topographies and current regimes could dominate the physical range arid
- ould be deleted. dynamics of drilling mud transport. The report also outlined the components
C7 vPa,-u---4-2ii-1d ti'@, of the drilling discharges but did not outline with any certainty the effects
Page 43, line 2 Replace I'material endangering the public health" with "public- on the flora and fauna that exist in the proposed Cordell Bank area.
69 health endangering material". Overall, arid without further information, NQM is unable to predict the
@ffects of oil and gas activities on the resources of Cordell Bank. NCAA has
=144,i5.t Res.urce Protection. Existing enforcement capabilities should be included within the scope of regulations, possible regulation of oil and gas
ed n his section (i.e., number of enforcement boats available in the area, activities, throughout the Sanctuary, to prevent immediate, serious and
frequency with which boats are detailed to this general area, manpower irreversible damage to the ecosystem of the area.
availability, etc.).
The EEIS/MP has extensively illustrated the variety and richness of
Page 46, 2. Framework for Research, bullet 2 doinicerning baseline studies, fish, algal, plankt-c, invertebrate and larval resources that are present on
"interaction of the riving resources" is a separate and complex category of studies Cordell Bank and are potentially threatened by hydrocarbon activities.
70 and is better placed within "predictive studies".
67. Health and safety hazards refers to the c=nonly accepted threat of
ramework for Research bu t 1. Add "manipulative" to the bioaccumulation of toxins through the food-chai erhaps to
43@ -tF_1@@_ n to humans and also p
dies category. Also, in . .cussion of baseline studies, any direct effects Ito humans such as fishermen and swimmers.
71 relMatiFot'n"s"h@ip"ts"between the biota and physical/chemical factors and human activity
on fishes are mentioned. Clarify whether there are plans to study interspecific 68. Comment accepted. The tAxt has been clarified in the FEIS/Mp.
relationships among the marine oganisms.
74? Page 47, (b) "what is happening" is not clear, replace with "changes in the long 69. See Generic Response G.
term". 70. Camient accepted.
"This program should include ... and studies to monitor the dynamics of species 71. Ideally manipulative studies will be done but riot in the rear future. It is
competition for space." Studies of species' competitive interactions would be a first necessary to conduct more basic descriptive researct, and monitoring in
73 predictive type study that would involve manipulation of species. It is the Sanctuary.
inappropriately placed within monitoring. The sentence would better read, "This
program should include . . . and studies to monitor the population dynamics of 72. Ihis has been corrected in the FEIS/MP.
species inhabiting upper reaches . . ."
Page 41; 1 election and Management of Research Projects. A timetable 73. This has been corrected in the FEIS/MP.
u.....i;i'It ese events would improve tracking them through time.

The decision to establish Cordell Bank as an NMS provides a rare and unique
opportunity for funding of research studies that will be of interest to several
agencies. As written, the plan indicates that the majority of decision and 74. C-t acoepted. NQAA fully intends to involve all local expertize in the
development of a studies program are left to the discretion and initiative of the development of a Sanctuary research program. N06AA bas always encouraged the
Sanctuary Manager. We recommend that: input of the private and public scientifc cammunity in achieving its research
a. A working group or joint committee similar to that utilized by the Minerals goals.
Management Service (MMS) Environmental Studies be formally
established. A working committee including representatives from National
17 Oceanic and Atmospheric Administration, U.S. Fish and Wildlife Service,
MMS, Army Corps of Engineers, Environmental Protection Agency,
National Park Service, and CDF&G would provide for input from more
groups, all of which serve to benefit from funded research.

. The Sanctuary Research Plan (SRP) should address "national marine 75- NQAA agrees- The Plan will address q0q1n
771 research goats."
C. Research on the banks should not be limited to sanctuary-sponsored
projects to the extent that outside projects do not affect other ongoing
research efforts. The "working group" approach suggested above would be
a valuabloaid in making decisions regarding concurrent research projects
conducted by outside groups. While this aspect of the SRP was alluced to
73 on page 50 (4.), the question of how outside research requests will be
approved or denied was not addressed. The mechanics at how data 76. Cq=nent aocepted. NoqM e,,,UrCj,,, the
generated by these projects will be disseminated or made public should be all research findings t:o the public as
clarified. In this respect, an automated data management plan should be
incorporated into this document so that electronic transfer, particularly
among agencies, will be facilitated. It will also be important to address
how research data and reports would be made available to the public.

Page 63. The Office of Strategic and International Minerals of MMS also has
70q71 responsibility for minerals on the Outer Continental Shelf (OCS). 77. Conuent acoepted.
40qQ4qM Page 63, last line. Replace "will" with "would". "Will" implies that the draft 78. This has been corrected in tile FqMq/Mpq.
EIS/Management Plan has already been accepted.
Pa e 618q.2.q,2q:unda2qj Alternative 2. It is unclear from Figures 2 and 6 whether the
P8q+
..4q7
d Y. the Cordell Bank NMS would be tangent to or touch the Point
Reyes-Farallon Islands NMS an its southeastern edge. If not, consideration might 79. ccqmrjent acoepted. qnle propo,
,d s,,,qbq,q,
be given to doing so, such that the sanctuary boundary is contiguous with the Point P-Yes-Ftq-110n National Marine Sanctqmqaqr
Reyes-Farallon Islands NMS in at least one place.
6qM"71 I 1--t III aragraph. Since an estimate of the cost required to manage the 80- Cq-q-t aoaept:,E@d. see Generic peqs
_U Bank NMS is included in Management Alternative I (page 70), a cost
estimate should be included for Management Alternative 2, as well,
Page 72, 6q=q,q, or.,Da6q=R so rees la.) ion. Since 4qAq9q2qPq-Orft 81. 14DAA intends to protect all benthic,
appear to prim y 2q@c 2qEs tqWe 8qZ6qOqVqI' "designed to protect, a OArrent CF&G and ROS regulations will
discussion of present management and/or laws protecting Allopora, their current include the ProhqWition of t1le rqmqwqal
8q831 qfffectiveness@ and how the sanctuary will improve this prqoqfqe2qetion should be al<Jae wit:hin the 50 fathcn iscibath arqour
included.
Page 73 Replace "Hydrocarbon Development Activities" with the beading 82. This has been oorrected in the FqM/Mp.
T "Hydrocarbon Exploration ajid Development Activities".
Page 73, 2aragraph 3. Replace "will" witb "would". 83. 7hiS has been corrected i,, the FqMq/MqPq.
8q*eic7 , whin, 9. Replace "Manager (RM)" with "Director (RDqY'; and replace 84. This has been corrected in the EyTS/Mpq.
0 eq@, tq6 "Region". 85. This has been corrected in the FEISq/MPq.
6q371 Page 74, line 13. Replace 11RM11 with "RD"; and "surface disposal" by "discharge". 86. This has been corrected in the FEIS/Mp.
0q34q81 Page 74, line 14 Replace "fluids" with "materials". 87. This has been, corrected in the FqM,,1qTq.
Page 74, line 19. Replace "RM" with "RD".

12
88- Ccmqwj7t accepted.
Page 74, line 20 Replace "disposition" with "onshore disposal". 89- Ckxmleqfqt aocepted.
Page 74, line 21 Delete the phrase "by barging,". 90. Congwnt accepted.
Page 76, line 12 Replace "generally" with "strictly". 91. Tb-is has been corrected In the FEIqSqIqNqP
Page 76, line 19 Delete the phrase "of oil spills". 92* Comiient accepted. NQAA prefers to keel
Pages 76-85. Impacts of regulatory alternatives should be discussed and analyzed q-tY IqMder one headirq.
separatelyqTpossibly as Part IV, Section I.A.5.) from the discussion of impacts due to 93- Oq_q_t accepted. be tet d,
sqa,
resource protection (Part IV, Section I.A.I.).
94. Comment accept@d. The sexite
xioe q&SqCqLqL
qsq@
79, raqgraph 2. Is there evidence that bioaccumulation actually occurs in hYdrocarbons on marine organsqw , q,
8q=eaqmqrqls is suggested in this paragraph? There is evidence that certain animal is intended to q-fer to marine maimials
groups (fishes and crustacea) do not accumulate petroleum hydrocarbons, for that q-y1ests tl-t certain spciq. of
example, as reported by Anderson et al., 1973. In: Symposium on Effects of t4q@re`gulatle (Caq-Y, F.G. and Teal, qj
Pollutants on the Physiological Ecology of Estuarine Organisms, Univ. South
Carolina. November, 1973. Bodied Sharks-" Cq-p- Biochem. physiqol.
161 P0qg--8q,oqdi,-- 17. Delete the phrase "interference with thermo-regulation" since 95. Ttle DEISq/MP does not state that a prqohqiql
ishes ,nt be'regulated if exploration and devel
hie organisms are not capable of thermo-regulation. fathqm isobath. The FEISq/MP has been
Page 85, line 5. The phrase "could be regulated by the sanctuary program" is regulatiq- q- Proposed, it wou1cl apqpi
7 1 inconsistent with earlier statements in the draft EIS. Clearly, activities "would" just within the 50-fathom isbth.
(not could) be regulated within the 50 fm isobath if the sanctuary were established.
96, NOAA agrees that tjq_ specific effects al
Page 85, 2. Research and Interpretation. Increasing public awareness of the Bank, difficult to predict. NOAA exrourage.
ut unforeseen i P,
may bring abo mpacts to the Bank and its resources, as inore vessels interested parties. 14CqM plans on cundqL
0q72q9 may be attracted to the area. This possibility (mentioned on pages 6 and 48) should determine the effects on the area.,
be specifically addressed and possible finpacts (disturbance to feeding marine considered as necessary. Also, see Gene
marnmals and seabirds; damage to Allopora due to increases in anchoring pressure)
discussed. 97, Sociogooncmic irqpacts are considered to
Pages 89 and 90. No analysis has been provided for socioeconomic impact to user corrected in the FRLSq/Mp.
groups, excursion boat operators, etc. If socioeconomic impacts due to the 98. Th- has been corrected in tlie FEISq/MqPq.
proposed action are negligible, it should be stated.
qCq) Page 99 There are two "Schmieder, R. W., 198411 references on this page. 99. Mqus has been corrected In the FqMq/Mp.
10q1 Page 102, paragraph I Replace "algaes" with "algae" and "fish" with "fishes". 100. Thl-s has been corrected in the FEisq/mqpq.
Page 103, Article 5. The phrase "Article 4, Section 1, paragraph (b)" should read 101. This has been corrected in the FEIS/MP.
q106q2 "Article 4, Section 1, paragraph (a)". 102. 7his has been corrected 1n the FEISq/Mp.
q14q6.0q3 Page 119, line 10. Replace "proldhits" with "prohibits". 103. 7his bas been COXTected in the FKrS/MqPq.
4qOqfq@ I Page 120, line 4. Replace %hore such" with "shore. Such". 104. This has been corrected in the FEISq/jMp.
4q02q5 1 Page 121, line 7 Replace "polution" with "pollution".
q10q06 1 Page 121, line 22. Replace "takers" with "tankers".

1071 Page 12 1, line 25. Replace "en route" with "enroute". 105. en route is an accepted spelling for
1048q31 Page 122, line 2. Insert "and 1985" after 111978,". 106. Ihis has been corrected in the FEIS0q/Mp
I 2q,.,Iine I l.. Replace "Secretarial Order No. 2974 of August 1978" with
)24qf4qf 107. Comnent accepted. For the Purpose of
4q08q11 qr also maintained.
4q0 Page 122, line 18. Replace "exporatory" with "exploration and development." 108. This has been corrected In the FEIS4q/qMqP
I Page 122, line 21. Insert "and 25611 after "Part 250". 109. This haseen corrected in the FEIS/MP
Page 1,22,, Ii ne 22. Insert 11, and OCS orders." after "particular leases" at the end of
the t, ce. 110. 7his has been corrected in the FElsqlqImp
113 Replace I'marerials" with "materials." 111. This has been Corrected in the FEIS0q/qMp

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IX
215 Fremont Street
San Francisco. Co. 94105

2 9 OCT 1987
Ms. Vickie Allin, Acting Chief
Marine and Estuarine Management Division
office of ocean and Coastal Resource Management
National ocean Service/NOAA
1825 Connecticut Avenue, N.W.
Washington, D.C. 20235

Dear Ms. Allin:

The Environmental Protection Agency (EPA) has reviewed
the Draft Environmental Impact Statement (DEIS) titled CORDELL
BANK NATIONAL MARINE SANCTUARY. Our detailed comments on
this document are enclosed.

Under the National Environmental Policy Act (NEPA) and
Section 309 of the Clean Air Act, EPA is required to review
and comment on this DEIS. We have classified this document
as Category LO - Lack of Objections (see attached "Summary of
Rating Definitions and Follow-Up Actions"). We support
creating a marine sanctuary to protect Cordell Bank. However,
we believe that the FEIS should analyze other regulatory
alternatives.

We appreciate the opportunity to review this DEIS.
Please send four copies of the Final Environmental Impact
Statement (FEIS) to this office at the same time it is offici-
ally filed with our Washington, D.C. office. If you have any
questions, please call me at (415) 974-8083 (FTS 454-8083) or
have your staff contact Harriet Hill at (415) 974-8193 (FTs
454-8193).

Sincerely yours,

Dea@na M. Wieman, Director
office of External Affairs

Enclosure (four pages)

CC: Department of Commerce, Wilczynski
National marine Fisheries Service, Kiraly 1234

Comments

We recommend that the FEIS analyze a broader range of al-
ternatives regulating hydrocarbon development activities
within the sanctuary. No regulatory alternative (RA)
excluding oil and gas activities from the entire sanctuary is
considered in the DEIS. Such an alternative seems "reasonable"
since similar regulations are in place for the adjacent Point
Reyes-Farallon Islands National Marine Sanctuary [15 CFR 935]
and the Channel Islands National Marine Sanctuary [15 CFR 936).

The DEIS discusses two RA's; "no immediate regulation" and
"immediate regulation of development activities." The former
is proposed as the preferred alternative because the present
OCS Leasing Program excludes the area of Cordell Bank within
the 50-fathom contour. The latter RA would prohibit oil and
gas activities within the 50-fathom contour, and monitor
hydrocarbon activities within one mile of the contour.
Both of the R.A.'s would permit oil and gas activities well 1. Ccoulent acoepted. NOAA concurs that such a regulatory alternative is
ithin the limits of the preferred boundary alternative, reasonable and has modified the FMS/MP acoordingly. Also, see Generic
which incl udes a buffer zone of three nautical miles beyond responses B and E.
the 50-fathom contour. Therefore, excluding hydrocarbon
activities from sanctuary boundaries would not duplicate
w

current OCS Leasing Program regulations.

To expand the alternatives analysis, we recommend that the
FEIS:

a. Examine a third RA which completely excludes oil and gas
activities from the sanctuary. The impacts of this RA
should be delineated for each of the three boundary
alternatives.

1) The environmental consequences of the three RA's should
be contrasted to sharply define the issues and provide
a clear basis for choosing among the options
[40 CFR 1502.14). The DEIS does not compare the
impacts of the two proposed RA's.

b. Describe the regulatory process that would serve to
exclude future oil and gas development under the preferred
RA. The FEIS should provide an implementation plan for
prohibiting future OCS leasing within the 50-fathom iso-
bath.

C. Disclose the distance between the 30- and 50-fathom
contours, and discuss in greater detail potential impacts
from authorized oil and gas development within sanctuary
boundaries.

-2-

In the DEIS, it is concluded that drilling discharges 2. The distance between the 30 and 50-fathom isobath is on average 17 nautical
beyond the 50-fathom contour would not harm biotic re- miles with a range between 2 and 30nm. The cited EPA study aibed how
sources, since most of the benthic biomass is found at different topographies and current regimes could dogunate the physical range
depths of less than 30 fathoms (p. 82). But the distance and dynamics of drilling mid transport. The report also outlined the
between the two contours is not given. A major EPA study coap-rts of the drilling discharges but did not OuUine with any certainty
(EPA 440/4-85/002, August 1985) was conducted to determine the effects on the flora and fauna that exist in the proposed Cordell Bank
the effects of drilling mud discharges. The study showed area. Overall, and without further information, NOAA is unable to predict the
that significant benthic impacts from platform discharges effects of oil arid gas activities on the resources of Cordell Bank. NOAA has
can be detected as much as two miles from drilling 1-110-1 with- the scope of regulations, possible regulation of oil and gas
sites. activities, throughout the Sarr_@ to prevent immediate, serious and
irreversible damage to the ecosystem of the area.
We are concerned that discharges at the 50-fathom contour
could seriously atfect the benthic communities proposed
for protection within the sanctuary. Without further
information, we cannot determine if a "no activity" zone
at the 50-fathom contour would adequately buffer Cordell
Bank biota from adverse effects.
3. The other National Marine Sanctuaries mentioned had plans for immediate oil
2. The FEIS should explain why the Cordell Bank sanctuary should arid gas development. It was NOAA's intention to protect the resources from
be managed differently for oil and gas activities than the this imminent threat. In addition both Sanctuaries have islands and coastline
two 0ther NationaI Marine Sanctuaries in California, the Point within their boundaries wtiich are much more vulnerable to the long-lasting
Reyes-Farallon Islands, and Channel Islands Sanctuaries. effects of an oil-spill which may impact beaches rookeries and haul-cut
Regulations issued for these sanctuaries specifically areas. These additional risks are not present for the resources of Cordell
exclude oil and gas development within their boundaries, Bank.
except for existing leases in the Channel Islands
Sanctuary.
3. The FEIS should explain how the present delineation of the 4. All of NOAA's National Marine Sanctuaries have boundaxies that attempt to
preferred boundary alternative (no. 2) is consistent with meet two objectives simultaneously. First, the Sanctuary is designed to
boundary determinations for the other California National excomPass as much Of the resource area as possible for increased protection.
Marine Sanctuaries. The DEIS states (p. 86) that the great Second, the goal of effective management and resource protection is
areas incorporated by boundary alternative 1, the largest constrained by the size of the sarcbjary due to the limited number of
alternative, "are undifferentiated in terms of living resources available resources and Sanctuary staff to effectively manage the area and
from most of the ocean waters beyond." Do the considerably enforce the regulations. The proposed boundary for the Cordell Bank National
larger Point Reyes-Farallon Islands and Channel Islands Marine Sanctuary was 1----i on analysis of the resources of the area, the
Sanctuaries contain only the 'well-defined environments" different human uses, e-StIng regulatory PrOgram and the available NQAA
(p. 86) needed to support their ecosystems? resources to provide an effective management regime. In general the boundary
represents a management unit wJuch closely approximates an area needed to
4. The FEIS should describe how the preferred boundary alter- protect the special resources of Cordell Bank. Also, see Generic Response A.
native would affect joint management with the Point Reyes-Far-
allon islands Sanctuary.

Under the larger boundary alternative (1), it appears that:
5. NOM agrees with both these ocuuents. NOAA has chosen the larger boundary
a. Protected resources could be more easily managed in the alternative (i) as the preferred boundary in the FEIS/Mp.
local area. Cordell Bank could be managed as a unit with
the contiguous Point Reyes-Farallon Islands Sanctuary.
Fewer sanctuary boundaries would also aid enforcement
efforts.

-3-

I
b. Significantly more habitat for marine mammals would be
protected. Although these animals are protected under the
Marine Mammal Protection Act, their habitat Is not.

S[MMY OF RATING DEFINITICINS AND FOLWA--UP ACTION*

Environmental impact of the Action

M-lack of objections
The EPA review has not identified any potential environmental impacts requiring
substantive changes to the proposal. 1he review may have disclosed opportunities for
application of mitigation measures that could be acccuplished with no more than minor
changes to the proposal.

EC-Ewironmental Concerns
The EPA review has identified environmental impacts that should be avoided in order to
fully protect the environment. (brrective measures may require changes to the preferred
alternative or application of mitigation measures that can reduce the environmental impact.
RER would like to work with the lead agency to reduce these impacts.

ED-Ermironmental Objections
The M review has identified significant environmental impacts that must be avoided in
order to provide adequate protection for the environment. ODrrective measures may require
substantial changes to the preferred alternative or consideration of some other project
alternative (including the no action alternative or a new alternative). EPA intends to
work with the lead agency to reduce these impacts.

EU-Environmentally Unsatisfactory
7he EPA review has identified adverse environmental impacts that are of sufficient magni-
tude that they are unsatisfactory from the standpoint of environmental quality, public
health or welfare. EPA intends to work with the lead agency to reduce these impacts. If
the potential unsatisfactory impacts are not corrected at the final EIS stage, this
proposal will be recommended for referral to the Council on Environmental Quality (CEO).

Adequacy of the Impact Statement

Category 1-Adequate
EPA believes the draft EIS adequately sets forth the environmental impact(s) of the
preferred alternative and those of the alternatives reasonably available to the project or
action. No further analysis or data oollection is necessary, but the reviewer may suggest
the addition of clarifying language or information.

Category 2-Insufficient information

The draft EIS does not contain sufficient information for EPA to fully assess environmental
impacts that should be avoided in order to fully protect the environment, or the EPA
reviewer has identified new reasonably available alternatives that are within the spectrum
of alternatives analyzed in the draft EIS, which could reduce the environmental impacts of
the action. 7he identified additional information, data, analyses, or discussion should be
included in the final EIS.

Category 3-Ina"te
EPA does not believe that the draft EIS adequately assesses potentially significant
environmental impacts of the action, or the EPA reviewer has identified new, reasonably
available alternatives that are outside of the spectrum of alternatives analyzed in the
draft EIS, which should be analyzed in order to reduce the potentially significant environ-
mental Impacts. EPA believes that the identified additional information, data, analyses, or
discussions are of such a magnitude that they should have full public review at a draft
stage. EPA does not believe that the draft EIS is adequate for the purposes of the NEPA
and/or Section 309 review, and thus should be formally revised and made available for public
comment in a supplemental or revised draft EIS. On the basis of the potential significant
acts involved, this proposal could be a candidate for referral to the CEQ.

*From: EFA Manual 1640, "Folicy and Procedures for the IL-view of FL-deral Actions Inpacting
the Environment.'

UNITED STATES
NUCLEAR REGULATORY COMMISSION
WASHINGTON, 0. C. Z0555

October 6, 1987

Ms. Vickie Allin. Acting Chief
Marine and Estuarine Management Division
Office of Ocean and Coastal Resource Management
National Ocean Service/NOAA
1825 Connecticut Avenue, N.W.
Washington, D.C. 20235

Dear Ms. Allin:

In response to the letter dated August 20, 1987 from Mr. Edward Wilczynski to
the Nuclear Regulatory Commission, we have reviewed the Draft Environmental
Impact Statement (EIS)/Managernent Plan prepared by the U. S. Department of
Commerce for the Cordell Bank National Marine Sanctuary. Our review was 1. M Response Necessary.
directed to whether the action described in the draft EIS involved matters
within our jurisdiction by law or special expertise or had any potential
impact on NRC licensed facilities. No potential effects were identified;
therefore. we have no specific comments on the draft EIS.

Thank you for the opportunity to review the draft document.

Sincerely.

aha, Nef, PMSB
@is uclear Reactor Regulation
cc: Edward Wilczynski

1987

U.S. Dewrt Commandant Washington, D C 20593-0001
United States Coast Guard Staff Symbol C-MFS-l
of Transportal@on Phone (202) 267-0495
United States
Coast Guard
16004

V 22 07
Mo. Vickie Allin
Acting Chief$ Marine & Estuarine
Management Division
Office of Ocean & Coastal
Resource Management
National Ocean Service/NOAA
1825 Connecticut Avenue, N.V.
Washington, DC 20235

Dear Ms. Allint

The Coast Guard has reviewed the Cordell Bank Marine Sanctuary Proposed
Management Plan and offers the following comments.
Laws and regulations pertaining to the proposed Cordell Bank National Marine I- See Generic Response G. NQAA is fully awarie of the constraints on the USCG at
Sanctuary (CBNKS) rely primarily on "at sea" enforcement. The management plan Present and does riot intend to add any further dentands for InCreased
fails to make clear the anticipated level of Coast Guard efforts to support enforcment- NOAA intends to info- the USX of the boundaries of the
the "at sea" enforcement. The Coast Guard routinely patrols the coastal SanCtxklry and of any new regulations that exist Inside the Sanctuary. NQM
waters of Northern California with surface units and aircraft from San only intends to make use of the current level of routine patrols fr(n surface
Francisco and other areas. However, resources dedicated strictly to -its and aircraft. Sanctuaxy staff will work in conjunction with the USCG
enforcement of CENKS regulations would not be available without relief from and use any 'nforflation that these Patrols Provide regarding violation of
Congress. This Is especially true where, in the management plan, NOAA regulations within the Sancbjary.
proposes regulatory alternatives that will generate additional CBMMS
regulations, thus increasing the Coast Guard's enforcement responsibilities.

In particular, page 45 states:

Sanctuary designation would have the effect of broadening USCG
enforcement responsibilities to include the enforcement of sanctuary
regulations. However, in the event that analyses of use patterns
after sanctuary designation indicate that additional surveillance is
required# NOAA will provide for more Intensive enforcement to protect
sanctuary resources.

The management plan fails to clarify how NOAA will provide for more intensive
enforcement. The Coast Guard cannot afford to provide resources that are
solely dedicated to the enforcement of the CBNMS management plan and its
regulations. The successful management of the Cordell Bank National Marine
Sanctuary depends on NOAA's ability to effectively plan, giving due
consideration to the limited resources of the Coast Guard.

In addition, the following changes should be made to the management plan as
indicated: 2- Mus paragraph has been added to the FEIS/Mp.

Page 43, lot paragraph, change to read: Under the National
Contingency Plan for the removal of oil and hazardous substances,
actions to control or remove such material endangering the public
health and the environment Is the responsibility of the On-Scene

Coordinator, with assistance provided by the Regional Response Team.
The U.S. Coast Guard Marine Safety Office in San Francisco will
provide the on-scene coordination for response to oil or hazardous
substances spills in the area of Cordell Bank. The Eleventh Coast
Guard District in Los Angeles/Long Beach will provide Regional
Response Center facilities. The On-Scene Coordinator will receive
scientific support from NOAA and assistance as necessary from the
Regional Response Team and other appropriate Federal and state
agencies.
Page 55, Section 3., U.S. Coast Guard, lot sentence: delete the words 3. Ibis has been corrected In the FEISIMp.
"all" and 'Navigable."
Page 62, 4th paragraph, 2nd line: After "Clean Water Act (CWA)", 4- Ihis has been oorrected in the wis/m.
add: "and the Comprehensive Environmental Response, Compensation and
Liability Act (CERCIA)."

Page 72, Section C.1.(a), lot sentence, change to read: "Under this
alternative, the provisions of the Clean Water Art (CWA), Comprehensive
Environmental Response, Compensation and Liability Act (CERCIA) and
the National Contingency Plan would provide some protection from 5. 1he text has been modified in the FEIS/Mp.
potentially harmful discharges. Discharges of non-biodegradable solid
waste in regulated under provisions of the Marine Protection, Research,
and Sanctuaries Act (MPRSA). Discharges of oil and chemical waste are
regulated under provisions of the Act to Prevent Pollution from Ships
(APPS)."
Page 88, 2nd paragraph, add 3rd sentence to read: "The Senate 6. 1he text has been updated in the FEIS/Np.
is considering ratification of Annex V of MARPOL 73/78 which when
implemented by U.S. law would prohibit the discharge of all plastics
into the marine environment."

Pages 119 and 121: The International Convention for the Prevention
f Pollution of the Sea by Oil, 1954, and The Oil Pollution Act of
1961 have been superseded by the International Convention for the 7. The text has been updated in the FEIS/Mp.
Prevention of Pollution from Ships 1973, as modified by the 1978
Protocol relating thereto (MARPOL 73178) and Implemented by the Act
to Prevent Pollution from Ships (33 USC 1901).

The Coast Guard appreciates the opportunity to comment on this document.

Sincerely,

Pivision
By direction of the Commandant

Copy: Mr. Edward Wilczynski, Acting Chief,
Ecology and Conservation Division,
NOAA

US Department 400 Seventh street 5 W
of Transportation Washington, D.C 20590
Maritime
AdmiMstration September 3, 1987

Ms. Vickie Allin
Acting Chief
Marine and Estuerine Management Division
Office of Ocean and Coastal Resource Management
National Ocean Service
National Oceanic and Atmospheric Administration
1825 Connecticut Avenue. N.W.
Washington, D.C. 20235

Dear Ms. Allin:

Regarding review comments on the Cordell Bank National Marine Sanctuary,
Draft Environmental Impact Statement/Hanagement Plan, I have reviewed
the document and have the following comments, corrections and
suggestions.

COMMENTS:

Overall the concept of a Marine Sanctuary is appropriate for the Cordell
Bank area and the study of options and suggested areas seem to be very
well planned.

There seems to be a lot Of consideration given to possible oil 1. No ResporLse Necessary.
produc tion and oi 1 spiliain the area and their implications.

CORRECTIONS:

Pg ii Page numbers need to be corrected for items Sec. 11, C.3 and 2. 01is has been corrected in the F=/MP.
See. III B.5.
Pg iii Under Sec. IV D. the 2. Sanctuary Manager ... 57 was left 3. Ihis has been corrected in the FEIS/MP.
out of the listing and National Park Service ... 58 should 4. This has been corrected in the FEIS/MP.
be 3. not 2.
5. Ibis has been ciorrqct@ed in the FEIS/Mp.
Pg iv Sec I A.1.Regulatory Protection Regime rather than Regulatory
Enforcement Regime. 6. Ittis bas beeri ciorlected in the FEIS/Mp.

Pg v Part VIII the title of Appendix I does not agree between the
Table of Contents and the Appendix and there was no list of
abbreviations in Appendix 3 on page 125.

Pg viii I think the "Affected Environment" should have referenced
Part 111, SecLion 11 not Part TI, Section II and the pages
would be 64 nut 63. Also page numbers for Par IV,-.
Section 1, 11 and III need to be correct-ed.

Pg ix Page numbers need to be corrected. 7- Mils has been q_Wrected In the FEISq/qMqpq.
Pg xi Last paragraph, first sentence use Arabic number 2 for 8. ItLIS has been corrected in the FEIS/qMP.
appendix.
Pg 12 Under A.l. sixth line in the paragraph which starts 9- qMq- has be- q-rrated in the FE:[Sq/qMP.
"Cordell Bank is located" should have said 10. Ibis has been corrected in the Fq=/Mp.
" ... 9.5 miles long and 4.5 miles wide ..."
0 Pg 33 Under 2. last sentence of first paragraph delete "were" 11. This has been corrected in the Fq=4q/qmqpq.
after tracts. 12- 1his has been corrected in the Fq=q/qMqPq.
Pg 41 Under 2. second line of first sentence insert
"(Section 1)" and delete "the". 13. This has been corrected in the FEsq/qmqpq.
12 1 Pg 55 Second line replace "he" with "the manager". 14. This has been corrected in t1le Fq=q/qMpq.
Pg 105 Appendix 1, there should he some title or division
3 1 indicating the start of "proposed regulations".
6q14 Pg 124 Appendix 3 is missing.
SUGGESTIONS:
15- NOAA originally considered the idea qoqf
It is suggested that the Management Plan be clearly separated from the there was tOO m1ch rq%yetition of materqiqi
Environmental Impact Statement even to the extent that it could be a information. ibe FEIsqImp has the Sa8qm
151 separate document or printed on another color of paper in the single facilitate canparison and review. Dif
document. clarit:y as the parts for the NEpA
There should be more information addressing the implications of the conbined and are not Separate setioqrq..
Marine Sanct uary Sta tus on commercial fishing and if this will allow an 16. See Generic Response I.
q10q6 inbalance in the species if fishing is stopped, continues or increases.
You do not have to give the answers; but, should discuss the possible
options. 17. See Generic ReSpCnse H.

There should be some more information on the effects related to merchant
6q7 shipping in terms of how the Marine Sanctuary Status would impact shipping
activities in the area, if indeed there is any impact.
18. Due to the small area involved and the I
Overall your document appears to represent a lot of consideration of the fishing, NQAA does not believe that theqr
Cordell Bank resources from a scientific view; however, a little more impact with &--tuary designation.
effort on commercial utilization by fishing fleets and impacts on
shipping activities would be useful.

We appreciated the opportunity to review your document and hope you find
these comments helpful.

Sincerely,

W. LLOYD FINK
Division of Engineering
Office of Naval Architecture
and Engineering

CC.
Mr. Edward Wilczynski
Acting Chief
Ecology and Conservation Division
Room 6814
National Oceanic and Atmospheric Administration
U.S. Department of Commerce
Washington, DC 20230

NA"

DAN HAUSER

CHAIRMAN
COMMITTEE ON HOUSING AND COMMUNITY DEVELOPMENT

September 29, 1987

Mr. Edward Wilczynski, Acting Chief
Ecology and Conservation Division
U.S. Department of Commerce, Room 6814
Washington, DC 20230

Dear Mr. Wilczynski:

As the Legislator representing the 2nd Assembly District,
I authored AJR 91, co-sponsored by Senator Barry Keene. Enacted
in 1986, this Resolution calls upon the Congress of the United
States to create a marine sanctuary on the California Coast.

I have asked my representative to be here this evening to
express my strong support for the federal designation of the Cordell
Bank National Marine Sanctuary. i. see cienexic PRspcnse B.

I would like my position to be very clear that I support the 2. See Generic Respome A.
rohibition of the OCS gas and oil leasing, exploration, development
nd pipeline construction activities, and that this prohibition
hould be included in the Boundary Alternative #1 from the beginning.

I am committed to the constituency of the North Coast and their
desire to protect the coastline of California. The creation of
the proposed Cordell Bank Marine Sanctuary would assure at least
a portion of the coastal protection I seek.

Sincerely,

7-S-76
Dan Hauser

DH/ge
oa W

STATE OF CALIFORNIA-THE RESOURCES AGENCY GEORGE DEUKMEJIAN, C.-

CALIFORNIA COASTAL COMMISSION
631 HOWARD STREET, 4TH FLOOR
SAN FRANCISCO. CA 94105
(415) 543-8555
October 8, 1987

Ms. Vickie Allin, Acting Chief
Marine and Estuarine management Division
office of Ocean and Coastal Resource Managment
National Ocean Service/NOAA
1825 Connecticut Ave., N.W.
Washington, D.C. 20235

Re: Cordell Bank National Marine Sanctuary; Draft Environmental Impact
SLaLemenL/management Plan

Dear Ms. Allin:

Thank you for the opportunity to comment on the DEIS for the Cordell Bank
National marine Sanctuary. The following are the Coastal Commission
staff comments.

Commission staff strongly supports the designation of the sanctuary, and
applauds the plans for research and education. 111hrough this effort the
public will be able to greatly enhance their understanding of the bank
and its importance to the ecology of the central coast. Cordell Bank
sustains a unique benLhic community, and is surrounded by a highly
productive foraging area for rockfish and other finfish, seabirds, and
marine manials. The bank also supports both commercial and recreational
fishing.

The resource protection afforded by the proposed sanctuary regulations
and proposed boundary is, however, quite inadequate. We strongly
recommend that:
1. Hydrocarbon exploration and development activities, including 1. See Generic Response B.
seismic surveys, be prohibited, and regulations implementing this 2. See Generic Response A.
hydrocarbon ban be a part of the initial designation document.

2. The boundary include a much wider area; we support boundary
alternative #1.

These changes to the plan will substantially lessen the likelihood of oil
spills reaching the bank and the waters surrounding it, and prevent
drilling discharges and seismic survey activity from damaging the
resources and current uses of the bank. These impacts and risks are well
enough understood at this Lime, and should be regulated from the outset.
Later monitoring will, in the case of oil spills, only provide an
assessment of risks and/or damage. Contingency plans, while worthwhile,
are unlikely to result in much protection for the resources. Prohibition
of hydrocarbon exploration and development activities at the bank and
within the surrounding area will provide much better protection.

-2-

under the regulations as proposed, birds and marine mammals will be
protected from hydrocarbon exploration and development activities
while within the Gulf Of the Farallones Marine Sanctuary, but will
not be protected when they Move to the waters surrounding Cordell
Bank to forage. cordell Bank and the surrounding waters are key to
the continued maintenance of the abundant populations of seabirds
and marine mammals so unique to this area of the Central California
Coast. To protect these resources Within the Gulf of the Farallones
Marine Sanctuary and not within the Cordell Bank Marine Sanctuary is 3. The fifty-fathclm isobath represents an
inconsistent. point for ttie resources of Cordell Bank
pelaq' ale fq-Id above the 30@fathqoqm
1)esignaLion of an area contiguous with the Gulf of the Farallones gic and dq--q-al- species that depe,
Marine Sanctuary, i.e. boundary alternative #1, is necessary to f-mid within the 50-fathqm isabath.
adequately protect the resources. Regulation enforcement and
aanagement will be very difficult if the boundary is small and The monitoring Provision now appI
separated from the current sanctuary, as is true of boundary regurement of a monitoring
alternative #2. to measure the effects of any hyd,,ca8qf8qt
Staff's specific comments and questions are as follows: see Generic Cournerlt 1. Nam
Possible fi--tleries research 11 Cordell
P. 42, (c) What is the rationale for the 50 fathom contour? Please valuable fish stoc@s.
expain how monitoring of the activity Within I nautical
31 mile will help.to protect resources. rro clarify the 4. NOAA is Preparing a contingericy ard
impact of the ilqUary operations exemption, information Marine sarbatuaries that will coordinate
on the contribution of these operations to harmful OXPerts in the event of an emergency
discharges should be included in the ETS. will assist in the ooordination of ef
defined@ and that adeguate resq@ ar
P. 42, 3. Oil spill contingency plans for the marine sanctuary orcianizations for bird clewling opeqmt
should include marine wildlife cleaning and PRsPOnq- Plan.
rehabilitation, especially for birds. Bird cleaning has
been done successfully, but unnecessary mortality has 5. NOAA will work in cOnlurctlOn with thqe
resulted from confusion over responsibilities and to the Sarctuary resources fqm
funding.
P. 44, 5. Assessment of the impacts and risk to marine resources See 'q-q-ic Responses A and F.
from commercial shipping should be included in the See Generic Response B. The provisions
research/monitoring plans, along with recommendations for 1972 and the Endar4q@ Species Art
lowering or mitigating this risk. endq-qp-red _pq_iq_, respectively, with
under both acts to Include harassment.
P. 64, 1. Boundary alternative #1 would not only provide more than a negligible impact an the speci
protection for marine mammal habitat, it would also Sq-tiq- 101 (a) (5) of the MqWA. The
qerovide for more coherent management, enforcement, and be monitored by the Sarvatuary staff to
Interpretation, education and research programs. It will are jeopardized or threatened by the s.
be particularly difficult to regulate discharges which
are likely to affect the sanctuary when the area is as nq-q- Is q- apparent need to prop,
small as boundary alternative 12. duplicate curr-ent State and Federal
P. 75 Seismic survey impacts to both fish populations and activities described.
fisheries should be discussed in the 'Environmental
Consequences Of Alternatives* section. Regulations to
7 prohibit this activity near Cordell Bank should be
I included.

-2-

P. 82 Resource information points out that one of the special 8. EPA published an "Assessment of Environmental Fate and Effects of Discharges
characteristics of this area is the clarity of the water, from Offshore Oil and Gas operations (1985) that describes in detail the
which allows species such as Allopora californica to different components of the drilling fluids, cuttings and discharged atr.
grow. Therefore, a more detaTT-ecT71-sau-ssionof the However, Our understanding of the environmental transport fate and tcxicity
possible effects of drilling discharges is needed. What of these components is still not fully understood. Envirwmlental factzrs that
would be the extent of the plume, area of deposition, affect the dispersion and transport of discharged material include waves,
change in light levels, and expected change in bioLa current direction and velocity and bottom topogaphy. he environmental
(particularly algae) if drill muds were discharged in or effects of the drilling materials and fluids are therefore very difficult to
near Cordell Banks? While there is still disagreement Predict. NOAA has prohibited all discharges and depositing of harmful
about all the impacts of drill muds, there is general tha' enter the Sanctuary and -Jure Sanctuary resairoes. NQAA will
agreement that the area surrounding a drill site is cont- to -tor the Sanct--Y resources and the activities that could
impacted by discharge and deposition of muds and Potentially injure those resources.
cuttings. Please support in more detail the sentence at
the end of paragraph 3. Are the longshore currents that
much stronger than in other areas?

P. 85 Oil development activities should be regulated now. This
para I is a unique and special area which depends on very good
water quality. The purpose of sanctuary designation is
long-term protection. It is immaLerial that Cordell Bank
is not part of the current 5-year lease sale, since this
is only temporary protection. If regulations were added 9. See Generic Response B.
later, what is the procedure for doing so. Please
outline in detail what precautions could be taken, and
what improvements wade to contingency planning.

P. 86 3. more specific data on location of marine mammal siqhLings
should be part of this EIS. Page 26 only refers to
"Cordell Bank Vicinity" and the species descriptions (pp. 10. See response ramlDex 3.
26-29) are vague. We would like to see a map with
sightings, if possible.
P. 89 Staff agrees that long-term protection from the effects of 11. See Generic Response B.
para 3 hydrocarbon development activities is inadequate. Such
protection should be afforded this marine sanctuary
through a regulation prohibiting such activities.

Thank you for your consideration of these comments. If you have
questions, please call me or Susan Hatfield at (415)543-8555.

Sincerely,

Susan Hansch
Manager, Energy and Ocean Resources

042214

ocr W

94
A44

STATE OF CALIFORNIA-THE RESOURCES AGENCY GEORGE DEUKMEJIAN, G-
DEPARTMENT OF FISH AND GAME
1416 NINTH STREET
SACRAMENTO, CALIFORNIA 95814
(916) 445-3531

October 8, 1987

Ms. Vickie Allin, Acting Chief
Marine and Estuarine Management Division
Office of Ocean and Cloastal Resource Management
National Ocean Service/NOAA
1825 Connecticut Avenue, N.W.
Washington, D.C. 20235

Dear Ms. Allin:

The California Department of Fish and Game has reviewed the Draft Environmental
Impact Statement/Management Plan regarding the proposed Cordell Bank National
Marine Sanctuary, and while we are very supportive of the area being so designated,
we are concerned that the draft may not adequately address the issue of the
existing jurisdictions and management.

Th more adequately address our concerns, the Department recommends that on Page 103 1. 7his has been corrected in the ms/mp.
within Article 5, Section 1, the second sentence be amended to read, "All state and
federal regulatory programs pertaining to fishing, including Fishery Management
plans promulgated under the Magnuson Fishery Conservation and Management Act,
16 U.S.C., SS 1801 et seg., will remain in effect."

In addition, the Department recommends that on Page 115, under the listing,

"State

1. Q31ifornia Department of Fish and Game", the paragraph be amended to read:

n'The California Department of Fish and Game (CF&G)@ under the Fish and Game
Code (and Chapter 11 of the Administrative Oodel, regulates and manages a wide
variety of activities affecting the living marine resources found in the 2. niis has been corre&@ In the FEIS/Mp.
territorial sea and in the 200-mile wide exclusive economic zone. The focus of the
Department's activities in Cordell Bank waters consists of the enforcement of state
laws in areas that are not administered under federal regulations such as those
Fbderal authorities listed below."

I am sure from my reading of this draft that you did not intend to impact
Department management. I'm confident that appropriate changes can be made to
answer our concerns.

Sincerely,

Pete Bontadelli
Acting Director

cc: Edward Wilczynski, Acting Chief,
Ecology and Conservation Division, NOAA

cl
,e 41
'1@008ZQZ 0_1@1/

M e m o r a n d v m

To : Gordon Van Vleck Dote October 7, 1987
Secretary for Resources
1416 Ninth Street
Sacramento, California 95614

Attn: Projects Coordinator

From : Department of Fish and Game

Subject: Draft Environmental Impact Statement/Management Plan (DEIS/KP) for
the Cordell Bank National Marine Sanctuary, SCH 87092307

The Department of Fish and Game (Department) has reviewed the
DEIS/MP for the Cordell Bank National Marine Sanctuary. We concur
with the DEIS/MP finding that the Bank possesses resources and
habitat of special national significance and we strongly support
the proposal for the designation of the Bank and adjacent waters
as a National Marine Sanctuary.

in our view, the goals of resource protection, research, and
public education, as outlined in the DEIS/MP, are both worthy and
reachable. We see that existing recreational and commercial
fisheries will not be adversely affected by this proposal and are
encouraged by the fact that, should these goals be met, they could
be enhanced.

1,11 this notwithstanding, it appears to us that a majo -r provision
for the "@pirotection of the Bank's resources and conservation of
its habitat" is not adequate. We refer to the one relating to oil
.and gas development, which indicates that, should such development
be permitted in the future, a regulation may be promulgated see GeneriC Response B.
prohibiting operations within part of the sanctuary and requiring
monitoring in another portion. The prohibition zone in this case
is composed of those waters that lie within the 50-fathom isobath
and the monitoring zone is the area within 1 nautical mile of this
contour. We feel that the DEIS/MP substantially underestimates
the potential adverse impacts upon the Bank, its resources, and
their fisheries from oil and gas development nearby, and relies,
too heavily upon the fact that the Department of the Interior has
not included the immediate area in its current 5-year lease sale
plan. It is apparent that the aforementioned regulation does not
provide the necessary safeguards in the event that exploration and
drilling are proposed at a later date.

Additionally, the proposed size of the sanctuary in the Preferred
r See Gen8r.1c Response A.
Alternative (101 square nauti -al miles) is not sufficiently
extensive as to provide an adequate buffer to the hazards of oil
and gas industry operations, and its configuration leaves gaps
between its boundaries and those of the Point Reyes-Farallon
Islands National Marine Sanctuary (PRNMS).

Therefore, the Department recommends that the Final EISIMP select
Alternative I, which proposes a sanctuary of 397 square nautical

-2-

miles and whose borders are contiguous with those of the PRNMS, as
well as incorporate a regulation which precludes all oil and gas
development activities within the sanctuary.

Department personnel are available to discuss our concerns in
greater detail. To arrange for discussion, contact Robert N.
Tasto, Marine Resources Laboratory, 411 Burgess Drive, Menlo Park,
CA 94025, telephone (415) 326-0324.

Pete Bontadelli
Acting Director

Ms. Vickie Allin, Acting Chief
Marine and Estuarine Management Division, OCRM
National Ocean Service/NOAA
1825 Connecticut Avenue, N.W.
Washington, DC 20235
CENTRAL COAST OCS October 7, 1987
REGIONAL STUDIES
PROGRAM Dear Ms. Allin:
1725 Montgomery Street
San Francisco, CA 94 111
415 398-3355 As Supervisors of six coastal counties, we want to express our 1. See Generic Response A.
support for designation of the Cordell Bank Marine Sanctuary. We 2. See Generic Response B.
CENTRAL COAST r commend Boundary Alternative #1, to provide continuity between
COUNTIES t a Gulf of the Farallones and the proposed Cordell Bank Marine
Board of Control Sanctuary. We further recommend that the Sanctuary's management
policies include regulations prohibiting hydrocarbon activities.
SONOMA
Ernie Carpenacr The Cordell Bank area provides a rich diversity of biological resources
MARIN which are valued for their research and recreational value. The
Gary Giacomini richness of this habitat is also reflected by its importance to the
SAN FRANCISCO commercial fishing industry.
Nancy G. Walker
SAN MATEO The area is also very sensitive to pollution. Adequate buffers are
Anna G. Eshot) necessary to protect the Cordell Bank resources from activities which
could potentially damage these unique resources. Alternative #1 is the
SANTA CRUZ only alternative which could provide an adequate buffer. This
Gary Parton alternative also completes the logical continuity between the Cordell
MONTEREY Bank and the adjacent Gulf of the Farallones Marine Sanctuary.
Marc]. Dcl Picro
REGIONAL We further recommend that Sanctuary regulations include the same
COORDINATOR prohibition on hydrocarbon activities which apply to the Gulf of the
Warner Chabot Farallones Marine Sanctuary. Without this protection the idea of a
Marine Sanctuary makes little sense. Exclusion of the Cordell Bank
area from the Department of the Interior's 5-Year plan is not adequate
justification for postponing a decision on this critical management
policy. The area covered in Alternative #1 is small compared to the
overall size of the Central California Planning Area.

An extensive regulatory analysis was performed for the Commerce
Department In 1982. which confirmed the validity of continuing the
hydrocarbon activities ban in the adjacent Gulf of the Farallones Marine
lee Sanctuary. That analysis concluded that:
su
r

The boundaries were established to protect the unique biological
resources.

Oil drilling may result in one or more catastrophic oil spills.

A ban on oil drilling would not harm the oil industry since the area Is not a high
priority for oil development.

Existing technologies 11.9. slant drilling). would allow recovery of more than
1/2 of the oil and gas resources estimated within the Sanctuary.

We contend that similar conclusions can be applied to the proposed Cordell Bank
Sanctuary under the boundaries proposed In Aftemative qV. We therefore endorse
boundary Aftemative #1 and urge that the management regulations prohibit
hydrocarbon activities within the Sanctuary.

Respectfully,
VOLq,
Sonoma County Supervisor Emle Carpenter

ro8qf Superviqdo G2q*mlni

C County 6qWSan Francisco
Su a Walker

n Mateo MY Supervisor Anna Eshoo

Santa Cruz CouU Gary Patton

Monterey county Supervisor Marc Bel Piero

cc Senator Alan Cranston
ity 0q@d
pe
6qZn M4q:,Iq.6q;.t8q@y
_0q@q-, 4qW8q@2qeo

Senator Pete Wilson
Congressman Doug Bosco
Congresswoman Nancy Pelosl
Congressman Tom Lantos
Congressman Leon Panetta
Congresswoman Barbara Boxer

ADMINISTRATION BUILDING
SUITE 315. CIVIC CENTER
SAN RAFAEL. CALIFORNIA 94903
THE BOARD OF SUPERVISORS OF MARIN COUNTY TELEPHONE (AtS) 499-7331

October 7, 1987

Dear Ms. Allin:

This is to advise that the Marin County Board of Supervisors,
at its regular meeting on October 6, 1987, voted unanimously to adopt
Resolution No. 87-351 in support of the Cordell Bank National Marine
Sanctuary.

A copy of the Resolution is enclosed herewith.

very trq@qly0q/ours,

14AROLD C. BROWN,
Chai

HB/pf nil
,SJOI112
Enc.
Ark
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2qro-1-011 q@12q,p2q42q*
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Ch,irma, vi- Chairman CI,rk
1308 Rou"NSUIERE HAROLD C. BROWN JR. AL ARAMBURU GARY GIACOMINI 008 STOCKWELL MARGARBT P. COUNCIL
Sao R.f.al San Anselano Tib-n San Geroninto Novato Regular Meetinit
I. District Znd District 3@d District 41h District Sth District Tuesday. 9A.M.

RESOLUTION No. 87-351

RESOLUTION IN SUPPORT OF
THE CORDELL BANK NATIONAL ILARIIIE SANCTUARY

WHEREAS, the Office of Ocean and Coastal Resource Management of
the National Oceanic and Atmospheric Administration (NOAA) has prepared and
circulated a Draft Environmental Impact Statement on the proposed Cordell
Bank National Marine Sanctuary; and

WHEREAS, comments from affected governmental agencies and interest
groups on the Cordell Bank Sanctuary proposal are being solicited by NOAA
until October 12, 1987; and

WHEREAS, the coastal and marine resources of the County of Marin
would receive signifi-cant protection from federal designation of the Cordell
Bank National Marine Sanctuary; and

WHEREAS, the County of harin recognizes the extreme vulnerability
of the biological resources of the Marin coastline, Tomales Bay, and the
Gulf of the Farallones to environmental impacts associated with OCS oil and
gas exploration and development;

NOW, THEREFORE, BE IT RESOLVED, that the Board of Supervisors
of the County of Marin hereby expresses its support for federal designation
of the Cordell Bank National Marine Sanctuary; and

BE IT FURTHER RESOLVED, that the Board of Supervisors of the
County of Marin supports the proposed "Boundary Alternative #11' for the I. See Generic Response A.
Cordell Bank National Marine Sanctuary as providing the most substantial
protective buffer zone for Cordell Bank; and

8 E IT FURTHER RESOLVED, that the Board of Supervisors of the
County of Marin supports a prohibition on OCS oil and gas leasing, exploration,
development, and pipeline construction activities to be applied to the full 2. See Generic Response B.
geographic extent of the Cordell Bank Marine Sanctuary at the time of
designation of the Sanctuary; and

BE IT FURTHER RESOLVED, that a copy of this resolution be forwarded
to the following two addresses to arrive prior to October 12, 1987: Ms. Vickie
Allin, Acting Chief, Marine and Estuarine Management Division, Office of
.Ocean and Coastal Resource Management, National Ocean Service/NOAA, 1825
Connecticut Avenue, H.W., Washington, D.C. 20235; and, Mr. Edward Vilczynski,
Acting Chief, Ecology and Conservation Division, Room 6814, U.S. Department
of Commerce, Washington, D.C. 20230.

PASSED AND ADOPTED at a regular meeting of the Board of Supervisors
of the County of Marin, State of'California, held this 6th day of October,
*1987, by the following votet

AYES: SUPERVISORS Al Aramb-uru,.Bob Stockwe-11, Gary Giacomini,
Harold Brown, Jr.
NOES: -

ABSENT: SUPERVISOR Bob Rouniguiere

CHAIRRAII OF THE BOAWOF SUPERVrS-ORS

MONTEREY COUNTY

THE BOARD OF SUPERVISORS
KARIN STRASSER KAUFFMAN, CHAIR .185
I@ GUAjITo RQAO
MONTEREY, CALIFORNIA 93WO

MARC J. DEL PIERO, VICE CHAIR
P oBOX 7 7
CASTAOVLLE CALIFORNIA %1)12

BARBARA SHIPNUCK
P a Box,_ September 30, 1987
SALINAS CALIFORNIA 93%2

DUSAN M. PETROVIC
P o Box NIS
KING CITY, CALIFORNIA 939"

SAM P. KARAS
1200 AGUAjITO ROAD
MONTEREY. CALIFORNIA 93UO

Ms. Vicki Allin, Acting chief
Marine and Estuarine Management Div., OCRM
National Ocean Service/NOAA
1825 Connecticut Avenue, N.W.
Washington, DC 20235

Dear Ms. Allin:

Monterey County wishes to go on record in support of the
creation of a near 400 square nautical mile Cordell Bank I - SOB Generic Response A.
National Marine Sanctuary offshore the Point Reyes National
eashore, as identified in Alternative #1 in the Draft
EIS/Management Plan for the Sanctuary. We believe the rich
concentration of marine life created by the unique Cordell Bank
deserves the protection guaranteed by a National Marine
Sanctuary. The Cordell Bank area contains a prolific assortment
of benthic organisms, large quantities of commercial fish,
feeding grounds for fourteen species of marine mammals and at
least forty-seven species of seabirds. Four endangered species,
including the humpback whale, the blue whale, the brown pelican,
and the short-tailed albatross have been observed near Cordell
Bank.
* e Coardell Bank National Marine Sanctuary should also contain 2. See Generic Response B.
* ban on all outer-continental shelf oil and gas leasing,
exploration, and development activities as part of the
regulatory framework for the entire Sanctuary. Establishment of
the Cordell Bank Sanctuary, contiguous to the existing Point- 3. The two Sanctuar-ies have resources that are uniquely distributed both
C
c
N

h
@e
th
eyes-Farallon Islands National Marine Sanctuary will provide a t-Porally and spatially. A different managment regime is necessary to
lo ical and continuous scheme of protection. Also, the two effectivly manage the two types of Sanctuary enviravmIent. Hadever, to
9 minimize costs, the same management facilities will be used by staff from both
Sanctuaries should be combined to facilitate management and Sanctuaries.
administration thereby providing the most economical and
[effective method of affording protection to the sensitive
C@
Cordell Bank area.

Letter to Vickie Allin
page -2-

We appreciate your thoughtful consideration of our comments.

Very Truly Yours,
VAII@
Karin Strasser Kauffman, Chair
Monterey County Board of Supervisors

KSK:SM:mc

cc: Mr. Edward Wilcynski, Acting Chief, Ecology and
conservation Division, Dept. of Commerce and Mr. C. WIlliam
Verity, Jr., Secretary Designe, Dept. of Commerce

71P
8@49eq -to

Departn2ent of Envh-onmental blanagenjent BOARD OF SUPERVISORS
Planning and Development Division ANNA G, ESHOO
MARY GRIFFIN
Tom HUENING
E) Planning Division - 415J363-4161 TOM NOLAN
Mail Drop 5500 - 590 Hamilton Street - Redwood City - California 94063 WILLIAM J. SCHUMACHER
C1 Buililling Inspection Section - 4151363-4601 PLANNING OIRECTOR
Mail Drop 5514 - 590 Hamilton Street - Redwood City - California 94063 CHRISTINE M, GOUIr
COUNTY OF SAN MATEO

October 8, 1987

MS. Vickie Allin, Acting Chief
Marine and Estuarine Management Division, OCRM
National Ocean Service/NOAA
1825 Connecticut Avenue, N.W.
Washington. OC 20235

Dear Ms. Allin:

We have reviewed the Draft EIS/Management Plan for the proposed Cordell Bank
National Marine Sanctuary and wish to express full support of the proposed
designation of Cordell Bank as a National Marine Sanctuary. This marine
habitat is highly valued for its rich array of biological resources; thus, it
deserves the kind of protection that will enable it to flourish and to benefit
future generations.
W:tbelieve that Boundary Alternative No. I provides the greatest buffer
b ween the proposed sanctuary and potential future OCS oil and gas develop- 1. See Generic Response A.
ment. In addition, it provides a logical link between the proposed Cordell
Bank Sanctuary and the Gulf of the Farallones Marine Sanctuary.

Boundary Alternative No. I comprises only a small portion of the overall
Central California OCS Planning Area, and it is our understanding that the oil
industry does not consider this area a high priority for oil development. As
such, and given the proposed sanctuary's research, recreation and commercial 2. See Generic Response B.
fishing value, the County also strongly supports a permanent ban on OCS oil
and gas leasing, exploration and development activities within the sanctuary.
Staff recommends that the ban be applied at the time of designation.
If you have any questions regarding our comments, please feel free to contact
Maureen Riordan at 363-4161.

SlAcerely.

131418
@h e
riti M
a..in @Di e@ (0
CMG:MUR:kcd - KIE10197

.A,

PLANNING DEPARTMENT C 0 U N T Y 0 F S A N T A C R U Z

GOVERNMENTAL CENTER 701 OCEAN STREET SANTA CRUZ, CALIFORNIA 95060
(408) 425-2835

October 8. 1987

Ms. Vickie Allin, Acting Chief
Marine and Estuarine Management Division
Office of Ocean and Coastal Resource Management
National Ocean Service/NOAA
1825 Connecticut Avenue. H.W.
Washington. D.C. 20235

Dear Ms. Allin:

As planners of a central California coastal county we want to express our
support for designation of the Cordell Bank National Marine Sanctuary. The
County of Santa Cruz Planning Department and Board of Supervisors has long
been interested and committed to protecting the marine environment. The
Cordell Bank is a unique and rich natural resource of vital economic and
cultural importance to our coastal county. Our county, as other coastal
counties, is economically dependent on California's abundant marine re-
sources for both recreational and commercial fisheries and tourism. A
major percentage of fish harvested by our commercial fishermen are caught
at the Cordell Banks.
W
e have reviewed the proposed management regulation and while we feel they
are generally acceptable, there are several Major areas where they are
inadequate. To correct that, we recommend that the Sanctuary's management 1. See Generic Response B.
regulations include a prohibition on OCS oil and gas leasing, exploration,
and development and offshore dumping for the entire Cordell Bank National
Marine Sanctuary. We believe it is important to stress that currently
arvested marine resources are renewable in nature, whereas hydrocarbons
are a non-renewable resource. The existence of the renewable biological
resources are threatened by hydrocarbon activities. It is in the best
interests of the nation as a whole that renewable resources not be endan-
gered and that vital habitat for these resources be protected.

We would dISO like to point out that the portion of the proposed sanctuary
which is included in Boundary Alternative #1 (but excluded from Boundary
Alternative #2) lying to the north and west of the Gulf of the Farallones
National Marine Sanctuary, is heavily trafficked by commercial shipping,
including oil and chemical tankers and barges. We believe that the poten- 2. See Generic Resporise A.
tial for environmental disaster resulting from a collision or other similar
mishap should weight heavily in favor of Alternative Boundary #1 and the
'
a,
i,
@a
M,

exclusion of hydrocarbon activities. Alternative Boundary #1 also repre-
sents a logical extension of the Gulf of the Farallones National Marine
Sanctuary.

850

BOARD OF SUPERV 0 S
COUNTY OF SANTA CRUZ
(408) 425-22

GOVERNMENTALCENTER 701 OCEAN STREET SANTA CRUZ. CALIFORNIA 95060-4069

DAN FOIRBUS ROBLEY LEVY GARY A. PATTON SHERRY MEHL JOE CUCCHIARA
[FIRST DISTRICT$ (SECOND DISTRICTI [THIRD DISTRICTI (FOURTH DISTRICT) (FIFTH DISTRICT)

October 1, 1987

Ms. Vickie Allin, Acting Chief
Marine and Estuarine Management Division, OCRM
National Ocean Service/NOAA
1825 Connetticut Avenue, N. W.
Washington, D.C. 20235

RE: DESIGNATION OF CORDELL BANK MARINE SANCTUARY

Dear Ms. Allin:

I am writing with respect to the possible creation of a Cordell Bank Marine
Sanctuary, presently being considered by the National Oceanic and
Atmospheric Administration. The Marine Sanctuary is proposed to be located
on the outer continental shelf, twenty miles west of Point Reyes, in
Northern California. I am very much familiar with this area, having been
born in San Francisco, and having grown up in the San Francisco Bay area. I
now reside in Santa Cruz County, some 80 or 90 miles south of the proposed
Marine Sanctuary area.

I strongly support the creation of a Cordell Bank Marine Sanctuary. The
Cordell Bank area is of extreme biological significance, and is worthy of
marine Sanctuary designation. Further, I believe that of the two boundary 1. Sm Generic Resporze A.
alternatives being considered, it is c cal ortant that Boundary
riti ss, ' imly
Alternative #1 be selected. This wouTd, e nytiaT , extend the existing
oint Reyes-Farallon Islands National Marine Sanctuary to include all of the
areas around and affected by activities near Cordell Bank. I understand
that the DEIS lists a much smaller area, so-called "Boundary Alternative
#2," as a "preferred" alternative. I do not believe that the smaller
designation is to be preferred, since more protection would be provided to
the significant biological area of the Cordell Bank by the adoption of
Alternative #1, which extends the existing Marine Sanctuary.
IS R
01

@
in'
al
A

Ms. Vickie Allin, Acting Chief October 8, 1987
Marine and Estuarine Management Division Page 2

The Cordell Bank is an important and unique habitat that should be pre-
served. Creation of the proposed sanctuary. with adequate management
regulations, will help guarantee the survival of the Cordell Bank habitat
and the Important marine resources which it supports. Thank you for your
consideration of these comments. Please feel free to contact Donna
Bradford or myself at (408) 425-3069 if there is a need for further clari-
fication of these issues.

Respectfully,
o pjt@
Peter Cota-Robles
Resources Program Manager

PC-R/DB/lf

cc: County Administrative Office
Mr. Edward Wilcynski
Mr. C. William Verity, Jr.

ALLIN

@
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2
0

XTIV
N

October 1, 1987
Page 2

I think it makes sense for management of the new sanctuary to be
accomplished in connection with the management and administration of the
existing Point Reyes-Farallon Islands Sanctuary. I also believe that it is
important that whatever protection is ultimately provided to Cordell Bank, 2. See Gerieric Response B.
that a ban on OCS oil and gas activities be included.

Thank you very much for considering my comments on this important issue.

Yours truly.

GA A. PATTON, Supervisor
T d District

GAP:lg

1215U

_ @i2 3
P
%PATTON isor
T d strict@ Sperv

@234

COUNTY OF SONOMA
ERNIECARPENTER
BOARD OF SUPERVISORS ... II.A.
575 ADMINISTRAT10N DR., RM. ]ODA JAMES HARBERSON
SANTA ROSA, CAUFORNIA 95401 -L .....AN
1707) 527-2241 JANET NICHOLAS
HELEN RUDEE

NICK ESPOSH
EEVE T. LEWIS
CUUITY CLERK

Subject: Draft Sanctuary Management Plan for the proposed Cordell Bank
National Marine Sanctuary.

Dear Ms. Allin:

Thank you for allowing Sonoma County the opportunity to comment on the above
plan. Due to the importance of the marine resources offshore Sonoma County
and their significance to coastal fishing and recreation, the Board of
Supervisors has authorized me to submit these comments and the attached
resolution for your consideration regarding designation of Cordell Bank.
Sonoma County supports the designation of Cordell Bank as a National Marine 1. See Generic Response A.
Sanctuary. We recommend, however, that the boundary of the sanctuary
conincide with that identified as Boundary Alternative #1 in the Draft Plan.
We feel that this boundary best protects both the Bank resources and the
marine mammals and seabirds that depend upon them.

Sonoma County further recommends that the management plan provide for
immediate regulation of hydrocarbon development activities. Regulation should
include designation the entire sanctuary as a "no activity" zone for oil and 2. See Generic Responses B and E.
gas development. The plan should also include a monitoring program for both
baseline studies and impact assessment of existing oil and gas activities
(spills and discharges from tankers using nearby shipping lanes).

Thank you for your kind consideration of these comments.

Sincerely,
am 6
Ernest L. Car@pent
Chairman, Board of Supervisors

:csb
dn:cb/g/pg.6

#45.
Resolution No. 87-1826
Tid wni.jv INSTRUMENT IS P
CORRECT COPY OF THE ORIGJNAL Sonoma County Administration Building
ON FME IN THIS OFFICE. Santa Rosa, California
[..-,TEST: SEP2 91987 Date: September 29, 1987
LEVE T. LEWIS
(,ui Zy Clerk & ex-officio Clerk of the RESOLUTION OF THE BOARD OF SUPERVISORS, COUNTY
i jard of Supervisors of the St-te 01cal-OF SONOMA, STATE OF CALIFORNIA9 SUPPORTING
i;ornla, I is for the-county of Sunoma FEDERAL DESIGNATION OF CORDELL BANK AS A
L)""NATIONAL MARINE SANCTUARY AND AUTHORIZING THE
CHAIRMAN TO SUBMIT COMMENTS ON THE PROPOSED
SANCTUARY MANAGEMENT PLAN TO APPROPRIATE
AUTHORITIES.

WHEREAS, the Cordell Bank has been nominated as a candidate site for
designation as a National Marine Sanctuary by the U.S. Department of Commerce,
National Oceanic and Atmospheric Administration pursuant to Title III of the
Marine Protection, Research and Sanctuaries Act of 1972 as amended; and

WHEREAS, Cordell Bank supports a unique and abundant population of marine life
and consequently is an important feeding ground for many fishes, seabirds, and
marine mammals; and

WHEREAS, Cordell Bank waters are inhabited by large numbers of rock fish.
which support significant commercial and recreational fishing in the area; and

WHEREAS, designation of the area as a sanctuary would provide federal policy
and regulation of human activities which would give the highest priority to
protection of biological and fishery resources necessary for support of the
coastal dependent fishing industry; and

WHEREAS, such fishing industry is important to the coastal economy of Sonoma
County; and

WHEREAS, oil and gas development in the vicinity of Cordell Bank may have
significant adverse impacts on its biological resources and coastal fisheries;
and

WHEREAS, the designated sanctuary boundary should encompass not only the
marine resources directly attributed to the Cordell Bank but also the complete
feeding grounds and other habitats of marine mammals and seabirds associated
with Cordell Bank.

NOW THEREFORE BE IT RESOLVED that the Board of Supervisors does hereby support
federal designation of Cordell Bank as a National Marine Sanctuary, including
the area identified as "Boundary Alternative No. 1".

NOW THEREFORE BE IT FURTHER RESOLVED that the Board does hereby authorize the
Chairman to submit this resolution and related comments to the U.S. Department
of Commerce, National Oceanic and Atmospheric Administration and to the
appropriate public officials.

THE FOREGOING RESOLUTION was introduced by Supervisor

SUPERVISORS VOTE:
Nicholas: Aye Harberson: Aye Rudee: Aye Esposti : Aye Carpenter: Aye
ayes-. 5 noes: 0 absent: 0 abstain: 0

SO ORDERED.

_;OUNTY OF SONOMA T--
ERNIECARPENTER
BOARD OF SUPERVISORS -A-A,
575 ADMINISTRATION DR., RM. 100A JAMES HARBERSON
SANTA ROSA, CALIFORNIA 95403 -1 -.1 ...
(707) 527-2241 JANET NICHOLAS
HELEN RUDEE
EEVE T LEWIS NICK ESPOSTI
C-1 CL-K

September 29, 1987

Ms. Vickie Allin, Acting Chief
Marine and Estuarine Management Division
Office of ocean and Coastal Resource Management
National Ocean Service/NOAA
1825 Connecticut Avenue, N.W.
Washington, D.C. 20235

Dear Ms. Allin:

You have been presented a Resolution and letter under separate cover which
Indicate the position of the Sonoma County Board of Supervisors in supporting
sanctuary status for the Cordell Bank. The Board has chosen Alternative One,
the larger area. I would like to add additional comments as the Supervisor
representing the entire Sonoma Coast.

First, It to vitally Important that you support the expanded Cordell. Bank
National Marine Sanctuary. We are concerned that the Department of Interior
will lease these Important areas for offshore oil development to the detriment
the fisheries Industry, tourism, and the environment. I ask that you not 1. See GeneriC ReSPOnse A.
ly support the Sanctuary; the expanded boundary; but, that you ban all oil
0'
0
[exploration and drilling development within the boundary. 2. See GeneriC Response B.
Sonoma County is energy conscious. We have the largest geothermal-power
generation area In the world with the capability of producing 10% of
California's energy need. At the heightv before the price of oil declined, we
were producing 5% of California's power needs. The field Is currently
producing 1900 megawatts of energy today but we currently have a limited
market because of cheaper oil fired energy generation.

What an Irony. The steam developers can produce needed power but they can't
sell it because oil is cheap. When oil goes up, we sell efficient and
relatively clean power. The point: we can produce more power without offshore
oil to the benefit of the nation. Moreover, we need protection for marine
life as much as we need whatever limited oil reserves that may be found near
the Cordell Bank.

Hs. Vickie Allin
September 29, 1.987
Page 2

Finally, I ask that you allow fishing regulations to remain under California
Fish and Came and the Pacific Fisheries Management Council. They have
successfully managed the Channel Island and Gulf of the Farralones 3. See Generic Response I.
sanctuaries. Neither the County or I would have objections to both commercial
and sport fishing In the sanctuary area.

Thank you for your most positive consideration to this vital protection to our
marine environment.

ly
xZ9
Ernie Carpenter
Fifth District Supervisor

EC:po

COMMENTS RECEIVED AT HEARINGS

RESPONSE
jenner o3nqmnity Club, Jenner Coastside Conservation Coalition and Camittge Sea Generic Pq-4nnSes A and B.
to Save the Russian River, Septenber 29, 1987.
Suamary of caqments; by Mr. Hecht3man at the public Hearings on the
proposed Cordell Baqa National Marine Sanctuary at Bodega Bay, California.

We favor the prqqqmsal and determine the Sanctuary would en1qwq= the
fisheries. We support the Bmuxl-qay Alternative No. I and do riot want any
offshore drilling or development within the entire Sanctuary.

CCqREqW RESPCKSE

Environmental Action comuttee, Inverness Association and the Tonales Bay See Generic Responses A and B.
Association, September 29, 1987.
Summary of convents by Carl nzxqpr at the public Hearings on the proposed
Cordell Bank National Marine Sanctuary at Bodega Bay, California.

We support the Boundary Alternative No. I and we hope you will keep oil
cut of it.

OCHMERr RESPONSE
Bodega Bay Marine Iaboratory, Septenber 29, 1987. NDAA will develop a reseq@ progrqm to
Sumary of comments by Jim Clegg at the public Hearings on the proposed the Bank ecosystem. NOAA encourages th
Cordell Bank National Marine Sanctuary at BDdega Bay, California. OCq-Unity in organizing and executing
Responses A and B.
we favor the proposal and designate a Sarm::tuq@ and would conuur that the
research opportunities are fantastic. we support a Bourdary Alternative
larger than No. I and do not want any exploration for oil within the entire
Sanatuary.

CUMMERr FqMPCNSE
Friewds of the Coast, Septevber 29, 1987. See Generic Responses A, B and C.
Sumary of comments vade by qUonel ill at the public Hearings on the
proposed Cordell Bank National Marine Sanctuary at Bodega Bay, California.

We favor the proposal and want a ban on offshore oil drilling and on
sewage outfalls within the Sanctuary area. We support Boundary Alternative
No. 1.

CCbt4EUr RESPONSE
Summary of cruments made by an unidentified individual, at the public Hearugs See Generic Response I.
on the proposed Cordell Bank National Marine Sanctuary at Bodega Bay,
California, September 29, 1987.

I am concerned that there may be restrictions to fishing activities added
to the Sanctuary regulations in the future.

C0144EUr RESPONSE
Summary of comments made by Mr. Satery, at the public Hearings an the proposed See Generic P-POnses A, B and C.
Cordell Bark National Marine Sancbkuy at Bodega Bay, California, September
29, 1987.

I support the Sanctuary designation and would like to see the largest
possible boundary extended to include Bodega Canyon. I also wculd like to see
a ban on offshore drilling and a to consider the plans for a proposed sewage
outfall pipe.

CCt4MERr RESPONSE
Summary of comments made by Hans Schroeder, owner of Porto Bodega Marina, at See Generic ReSPQnse B.
the public Hearings on the proposed Cordell Bank National Marine Sanctuary at
Bodega Bay, California, September 29, 1987.

I support the designation of the Sanctuary and also Support a limited
right of entry to oil and conpanies for access to mining and exploring
offshore resources out of Bodega Bay.

034MERr RESPONSE
Summary of comments made by Richard Charter, at the public Hearings on the See Ge-ic P-POnse A, B, C.
Proposed Un-dell Bank National Marine Sanctuary at Bodega Bay, California,
September 29, 1987.

I support the Sanctuary designation and Boundary Alternative No. 1. 1
believe there needs to be a ban on all OCS oil and gas activities to the
entire Cordell Bank Sanctuary and a ban on the proposed sewer outfall.

COMMERr RESPONSE
Summary of comments mad by Ms. Wood, at the public Hearings on the proposed see Generic Response B,
Cordell Bank National Marine Sanutuary at Bodega Bay, California, September
29, 1987.

I stqoport the Sanctuary designation and )weping all oil interests out.

COM14ERr RESPONSE

Summary of comments made by Richard Nelson, at the public Hearings on the See Generic Responses A and G.
prcposed Cordell Bank National Marine Sanctuary at Bodega Bay, California,
September 29, 1987.

I support the Sanctuary designation and a larger boundary beyond and to
the North of Buxndary Alternative No. 1. to include another biologically
significant area. I also urge more mx-iey to be -d available to do the
proper kinds of research and patrols.

COMKERr RESPONSE

Summary of comments by Adrian Morgan, at the public Hearings on the See Generic Responses A and B.
proposed Cordell Bank National Marine Sanctuary at Bodega Bay, California,
September 29, 1987.

I support the SancWary designation and Boun:1ary Alternative No. 1 to
include Bodega Canyon. I believe there needs to be a ban on all OCS oil and
gas activities to the entire Cordell Bank Sanctuary.

C344ERr RESPONSE

Summary of comments norle by an unidentified individual, at the public Hearings See Generic Response B and H.
an the proposed Cordell Bank National Marine Sanctuary at Bodega Bay,
California, September 29, 1.987.

I am concerned about vessel traffic safety in the area and would like to
see a ban on the passage of oil tarkers within the Sanctuary. I also want a
ban on oil and gas activities.

CC144EUr RESPONSE

Summary of comments made by Alan Laterell, at the public Hearings an the See Generic Response A, B, C.
prqXSSd Cordell Bank National Marine Sancbkuy at Bodega Bay, California,
September 29, 1987.

I support the samcUkuy designation and B=xIary Alternative No. 1 to be
oTanded to include the bluffs and &xlega Canyon. I do not want to see any
OCS oil and gas activities or arry sewage within the Sanctuary.

COMKERr RESPONSE
Summary of comments by Michael Gold, at the public Hearings on the
proposed Cordell Bank National Marine Sancbkuy at RxIega. Bay, California, Comment accepted.
September 29, 1987.

I support the Sanctuary designation.

OOMMERr RESPCNSE
Center for Whale Studies, September 30, 1987. See Ceneric Response A.
Summary Of comments by Peter F'aloon at the public Hearings on the
proposed Cordell Bank National marine sanctuary at San Francisco, California.

We support the designation of the Sanctuary and prefer Boundary
Alternative Mo. 1.

CCMERr RESPONSE
Central California Oot=il of Diving Clubs, September 30, 1987.
Sulmmary of comments made by Clay Phipps at the public Hearings on the proposed See Generic Responses A and B.
Cordell Bank National Marine Sancbiary at San Francisco, California.

We support the designation of the Sanctuary and prefer Boundary
Alternative No. I coupled with the prohibition on hydrocarbon development.

CCHKwr RESPONSE
Sulmmary of comments made by an unidentified individual at the public Hearings see Generic Response H.
on the proposed Cordell Bank National Marine Sanctuary at San Francisco,
California, September 30, 1987.

I am concerned about shipping safety and accidental oil spills. I would
like to efforts made to reroute shipping traffic away from the sanctuary.

COMMERr RESPUIISE
Sumalary of caments made by an unidentified individual at the public Hearings See Generic Response H. Title 11 of the marine protection, Research and
an the pzvposed Cordell Bank National Marine Sanctuary at San Francisoo, Sanctuaries Act (the Act), which was recently reathori,ed by C"Wess and
California, September 30, 1987. signed into law on November 17, 1988, now Provides that a Portion of all
civil Penalties recovered for a violation of Sanctuary regulations be used to
I am conoerned about shipping safety and minimizing the risk of collision pay for storage and care of Sanctuary
in the vicinity of Cordell Bank. I also would like to see fines for resources and property -i..d during
violations, and for the payment of rewards for persons who furnish information
Sanctuary violations returned to NQAA for Sanctuary restitution and rE--@. leading tO an asses-lent of a civil penalty. In addition, the Act now
provides that NOAA may recover its emergency response and damage assesment
costs from penalties received for damages t. natural resources. Further, such
penalties are to be used to restore and replace or
.t resou@es whenever
possible, and to otherwise iEp-e the management of the Sanctuary, Where
resOuroes were damaged.

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