As many divers in the northeast USA know, we have had a concern with the lack of communication from NOAA regarding their intentions at the Stellwagen Bank National Marine Sanctuary. Specifically, the potential restrictions on diver access to wrecks in the sanctuary. We have previously posted this concern on our web site along with a response from NOAA in the form of a letter that was sent to WDM. As a result of further voicing our concerns, NOAA conceded to an interview with us to shed some light on their intentions, and hopefully allay some of our fears, or at the least explain the process and plan, something that was previously not available to us. That interview in it's entirety is below for you to read. We were hoping for a "point-counterpoint" opportunity, but as NOAA is in the middle of an "embargo" process that will not be possible. However, I would like to thank Craig MacDonald for making this interview possible, and appreciating the benefit of making such a concession.
Stellwagen Bank National Marine Sanctuary Interview with Craig MacDonald, Superintendent, Stellwagen Bank National Marine Sanctuary Conducted by Joe Porter, Wreck Diving Magazine April 6, 2006 Joe - I’m glad you were able to get approval through the different layers in the chain of command within NOAA for approval of the interview. Craig - There are just so many layers it takes time to get the request to the people who make the decision. Joe – Frankly, from our last conversation I was expecting that you would come back to me with the ability to discuss the discovery phase and not necessarily to do the full interview. So this is a good step forward. I wanted to go through some basic concerns or questions. First, what has been done to reach out to the wreck diving community and discuss their concerns with the proposed Action Plan? Because frankly, as I have mentioned to you before, up to this point, NOAA was illusive and as you stated it was because of the embargo. I’m not sure that everybody knows that there is an embargo time frame. And during this period where there is really no communication back and forth other than a general letter, the diving community can only conclude in their minds the worst. So maybe you can elaborate on that a little bit.
Craig - Sure, first of all quite honestly we didn’t have any sense that there was a strong interest on the part of divers to dive in the sanctuary. In fact we didn’t know that there was any activity at all as we went into this management plan in this stage of process. So there was no channel for us to specifically target wreck divers and communicate directly with them, so eventually we had a public scoping and comment period in the year 2000. It was open July 2 through Oct. 18 which is three and a half months. This comment period was publicized in the local and regional newspapers, on our website, in the federal register, and for those organizations that we knew had interest in the sanctuary, we approached them to access their mailing list and communication networks to get the information out to everyone we thought had an interest. And again, diving was not on our horizon, we just didn’t see it. We also held meetings (public meetings) in Mystic, CT, Woods Hole, Provincetown, New Bedford, Plymouth, Boston, Gloucester, MA, Portsmouth, NH and Portland, ME from September through October 18. Joe – Now, were these pre-announced public notices? Craig – Yes, they were in the papers and our website and the federal register. I know wreck divers don’t read the federal register, but it was out there in the newspapers. In 2003, we (Ben Haskell) who was the team lead for the Maritime Heritage Working Group gave a presentation at the Boston Sea Rovers conference titled “From Shipwrecks to Sea life, a tour of the Stellwagen Bank National Sanctuary.” We did also have an exhibit at the show. We have had a booth at the Sea Rovers every year from 2003 right through to this past conference in 2006. In 2004, we had an exhibit at the Metro West Dive Club Wrecks Symposium; Ben Haskell also gave a presentation on the sanctuary’s shipwrecks at the symposium. I think what is particularly noteworthy is the technical diver representative on the Maritime Heritage Working Group developed and distributed a diver survey at Sea Rovers for everyone who was willing to participate. She had 55 questionnaires returned to her and she made the results of those questionaires available to the working group for their consideration. Joe - May I jump in with a question on that? A few minutes ago you said you really didn’t think of divers in the early part of this, but yet you had booths at the Boston Sea Rovers conventions? Craig - We started there in 2003 and the public scoping ended in 2002. I believe subsequent to the conclusion of the scoping, we presented on the wreck of the Portland at the New England Aquarium. We have an exhibit there and I was approached by some technical divers after the presentation who said “Hey guys we’re out here, you should do things with us.” Joe - And this was what time frame? Craig - Oh this was probably November 2002. It was just after the whole scoping process. It was a seminar we put on with the New England Aquarium as part of a series. That was the first indication that I had that technical divers were interested in the sanctuary. One of the things we have been doing with the divers since 2001, actually it hasn’t dealt with technical divers interested in shipwrecks, but we’ve been working with the local dive clubs training them on fish and invertebrate identification. We have trained over 800 divers in this time period and we’ve been doing annual fish counts with the REEF association. For the last 2 years we have had the highest number of participating divers of any one day great annual fish count event that the REEF association puts on. Volunteer divers have contributed over 758 hours of bottom time conducting surveys as part of that program. Joe - But you didn’t know that there would be technical divers out on the wrecks? Craig - That’s right. Keep in mind that we really didn’t begin appreciating what was out there in the way of shipwrecks until about 2001. As we were doing the public scoping we also became aware of the archeological and historic importance of resources within sanctuary, and that’s when we became aware and doing the surveys and confirming the locations and iddentification of some of the wrecks. Joe - Did it start more from the pre-historic? Craig – No, no it started with John Fish and Arnold Carr who had been routinely surveying all around Massachusetts for shipwrecks. They both have full time jobs that relate to this interest. On weekends and vacations, at their own expense and with their own equipment, they were looking for shipwrecks and trying to identify them. They were kind enough to tell us “Hey there are wrecks out there with historical importance you guys should know about.” They told us where the Portland, the Frank A.Palmer and the Louise B. Crary were and we were able to go out there with a team from the National Undersea Research Center at the University of Connecticut and do side scan sonar surveys where they told us to look. Sure enough there was the Portland, the Frank A.Palmer and the Louise B.Crary. We had just hired a staff archeologist at that time, an intern from East Carolina University’s Program in Maritime Studies. We now have two archeologists on staff. But this has all been relatively recent, both the focus on the maritime heritage aspect of the sanctuary and the interest in working with the divers, and now worrying about the technical divers’ interest in the wrecks, has all happened in rapid succession since 2001. Getting back to Maritime Heritage Working Group member’s survey, she felt that she should be surveying the sentiment of all the divers that might be interested in diving out there. Joe - And when did she start doing that survey? Craig - She started doing that in February, 2004, it might have been March. She did it at the Sea Rovers Conference. I can read some of the results if you like. Joe - Sure. Craig - She didn’t say how many surveys were passed out, but 55 were returned to her. Some of the results she thought were notable. Most of the respondents knew about the sanctuary but only 17 out of the 55 said that they currently dive out in the sanctuary. Fifty-two responded they would like to dive in the sanctuary for reasons tied to wreck diving and lobstering. Thirty eight of the respondents typically dive in water less than 130 feet. Only 5 checked that they dive in water greater than 300 feet. Forty-one of the respondents knew that there were prohibitions about mooring or removing historical resources. I think this is important because it relates to one of the other questions. Forty-five of these respondents or 82% would be willing to give notification of their intent to dive on a shipwreck in the sanctuary by radio or phone. The information she gathered, even though it was only one person’s efforts, gave information to the working group before the action plan was finalized. That was really the first sense we had of the kind of diver interest within the sanctuary. Now again, all of these were not wreck divers (technical wreck divers) because the Sea Rovers attracts a broad range. In addition to presentations and exhibits at Sea Rovers and MWDC Wrecks, sanctuary archeologists also presented to the South Shore Neptunes Dive Club and Mass Bay Divers Dive Club. In 2006, we again exhibited at Sea Rovers. Craig McClean who is the Deputy Assistant Administrator of the National Ocean Service gave a presentation on diving to those who are interested in diving, and he also said he was available to answer questions that people might have on the Stellwagen Management Plan. Sanctuary staffers were available for any questions at our booth. At the Sea Rovers, Ben Haskell approached the Bay State Council of Divers, which is the umbrella organization of all the dive clubs within the state of Massachusetts, leadership and provided them a copy of the letter that I submitted to you and explained the proposed Action Plan and offered to present at the council’s spring meeting. Back in October 2005 I also had written a letter to the Bay State Council of Divers just to let them know that we heard that the divers had concerns. It was very similar to the letter I sent to you. Not in detail. It just indicated that we were involved in this process and that there would be an opportunity for people to comment on what we’re proposing or recommending. Joe - At that point you were well into the embargo? Craig - We were. Essentially questions and interest was carrying over to the other dive clubs. We wanted to let them know that we knew they were out there, and we would be happy to take their comments, but we needed to wait for a formal “comment period” to open. At the same time I had an interview with Jerry Shine, he’s a local scuba diver and well known author here in New England. He has a web site, Northeast Scuba Diving, and it listed a few questions and answers that were relative to the letter I sent out that he had posted on his web site. We are also revamping our web site and we’re putting more information for divers, so in about another month that should be up and people can see that. We certainly care for the concerns and interest being raised. We are trying to do things that facilitate access to the sanctuary. The revamped website with more information is one thing. If our budget allows, we are also planning on putting up a marker buoy on the Josephine Marie which is a steel hulled dragger that sank, which is not historically significant, but an interest to divers. We’ll add that to our website and let divers know where that is. Of course there is the letter that was sent to you and we plan on releasing the environmental assessment. Now we’re looking at fall (for the open comment period of the proposed Management Plan). One of your questions was relative to the amount of public comment time required under the National Environmental Policy Act (NEPA). NEPA only calls for a 30 day optional period for comment on a plan. We’re looking at doing 60 to 90 days just as we did previously. So we’re not looking to shorten public comment, in fact we’re looking at 60 to 90 days and we have every reason to expect NOAA would agree that 90 days is OK. But that decision is NOAA’s. When the Management Plan comes out even though it is a management plan for this sanctuary, it’s officially NOAA’s Management Plan. This is why we have these higher levels of review, it’s not just the sanctuary saying this is what we want to do, this is NOAA saying this is how we want to manage the sanctuary. It may seem a subtle distinction, but it’s quite important. Joe - So you expect 90 days for public commenting? Craig - I’m hoping that’s what we would say. Certainly you could say 60 to 90 day public comment period, which is 2 to 3 times what’s actually required under law. Joe - Did you have any other comments on this? Craig - No that was kind of long and windy but I guess that gave you kind of a sense that we haven’t been purposely excluding divers. You can tell from this that we haven’t distinguished between other divers and technical divers. We have just been viewing them as one constituency. I do see the need for the segmentation, there are distinct differences. Joe - It a disappointing that even though we are a small population, the wreck diving community wasn’t a little more involved. For whatever reason. But, maybe involved a little more early on. I guess that is kind of where we are right now and it is drawing interest of some people. We just have to remember even though it’s a growing group of people, it’s still a small niche, relatively speaking. So moving on to the next question. In the results of public scoping and public review, when I went through the material that I downloaded I think from your sight, I didn’t see any concern about human visitation due to scuba diving at the time. Yet, it seems to be a big focus in what I’ve read to make sure that it is controlled. My question is, if it wasn’t a concern by the public in the beginning (divers visiting the wrecks), why is there so much concern at this point about the diving community and the wrecks that are down there? Craig - Actually, there were public issues that were identified and scoping comments that were linked to this. If you go to our web site to the management section and go down the left hand column where it says “Work Group Problem Statements” and then you actually open up the complete report and go to the “Maritime Archeology Working Group”, go to that and you’ll see the summary and at the very end of the documents on page 62 under 5B we’re actually looking at the kind of comments that were raised. There are two of them, one that says “Do not turn this sanctuary into a public dive site”, and the other one “Protect cultural resources such as the shipwreck of the Portland from all disturbances”. This isn’t the measure of how many times this sentiment was expressed. What we did was go through the 20,000 comments received and capture the sentiment, and try not to duplicate it multiple times. From this list I can’t tell you whether it came from one person, two people or more people. I would have to actually go through all the original comments and count each comment which I haven’t done. But, the important thing is when we do our scanning of the comments, what we are trying to do is gather the essence of public concerns. It’s not weighted by how many people are saying the same thing. A good example is that we may get an email message saying that we support this or we support that. We can get a thousand of them. That is a single statement of the concern. We know it came from a thousand people but for the purposes of identifying issues of concern it doesn’t matter whether one person or a thousand people said it as far a capturing what the concern was. So again, it pales in comparison to the number of issues that were actually raised like whale watching and commercial fishing. But it was an expressed concern that we captured. A lot of the discussion that grew around divers actually grew out of the discussions of the working group. The scoping comment information was given to the respective work groups. And then they went about their business. One of the challenges we have is that we want to facilitate compatible use. We want to make the sanctuary accessible to a variety of users. But the underlying provision is it has to be a compatible use. So one of the challenges of the working group is where we have historic resources, some which are very fragile, the first order of consideration is protecting them and then looking at any uses of that resource. It has to pass the test of compatibility. If it doesn’t, there are mitigations that have to be done to make the use compatible. So that’s the exercise that the working group was asked to go through. One of the concerns for shipwrecks of particular historical importance was we don’t want them damaged, we don’t want them degraded. And wrecks like the Portland, the Frank A.Palmer and the Louise B.Crary that we looked at with our ROV are very fragile. So there’s the overall concern. Given the fragility of sites like the Portland and the Frank A.Palmer and Louise B. Crary which are so well preserved yet fragile, what are appropriate uses?. The issue of access to divers became of considerable importance to those sites. Now, in comparison to what the Working Group called “Public Access” diver access wasn’t structured as clearly. I think we can simply describe it as the need for “compatible access” but it has to be mediated with doing anything which would make the wrecks more vulnerable to damage. So protecting them is first order of business and then we can facilitate access. Joe - That’s fair enough. I mean I understand your point there. And I guess going back to the question. It was an oversight on my part. I didn’t see there that it had been brought up early on as a concern. I fully understand protection is the first order. Then hopefully figuring out a way to have public access to it and protecting it after that. Going on to the next question then. Maybe it’s a misunderstanding on my part but the protection plan itself, the whole process of notifying the sanctuary that people going out to dive a site, or the concessionary program that was proposed for the charter business, all of this seems to be more restrictive than a model that seems to be working such as the Thunder Bay National Marine Sanctuary. Of course that model prohibits things that we all want to prohibit in that fresh water sanctuary such as recovering anything from the wreck, altering them, destroying in any way, possessing anything from the wrecks, anchoring on a wreck, etc. And if that model seems to be working, why do we need a model that is different or more restrictive than the Thunder Bay Marine Sanctuary model? Craig - Right. Let’s put this in a perspective that relates to your other questions having to do with the “Discovery Phase”. Let me begin with that and then I can add to it. Joe - OK. Let’s go into the “Discovery Phase” then and then we’ll come back to the Thunder Bay. The time frame for the “Discovery Phase” seems to be vague and I can appreciate the fact that you can’t say on a particular date you’re going to have all of the wrecks investigated for determining whether they should be “Public Access” sites or not, but it seems to have no ending date. We just want to make sure from the wreck diving community’s perspective that it’s not a case of “once this all starts, everything is in the Discovery Phase, that no wrecks can be access until all wrecks have been assessed. And Oh by the way when is that going to be? You know what I mean? Craig - OK. There’s a fundamental misunderstanding here. If you forget the title the “Discovery Phase”, it is no different than the “status quo”. Right now as long as you’re not damaging any of the wrecks you can dive on any of the sites. The only thing that is going to happen is as the sanctuary finds additional sites and we’re doing the assessments of the inventory, we just won’t release where the location of the wreck is until we’ve completed our baseline work. So, no one is being prevented from diving on those sites if they know where they are. Joe - So divers can dive the site if they know where it is, and until you have determined whether or not it is a historical significant wreck. Is that right? Craig - It could even be a historically significant wreck, but we may not feel it needs the protection of the preserve. In which case it’s a historic dive site and we will be telling people where they are. What we envision is something along the lines like a “historical shipwreck trail”. We know where about a dozen sites are now. Out of that dozen there are really only two that we feel merit heritage preserve status. As soon as we complete investigation of the others, their location will go up on our web site…here’s what it is, here’s where it is. We’re looking into developing a full blown outreach program with wreck divers, so that they know what they are diving on and the wreck’s history. They will be able to go to our web site and read up further on it. Section 2 Joe - And all you ask is that divers let the sanctuary know when they go out to dive a site? Craig - That’s right. Joe - And the purpose for the notification is what? Craig - The purpose for that is when we’re doing the inventory and assessment work we’re doing a lot of baseline documentation. We don’t want to see these sites being deteriorated. We want to manage these sites for long term use. By reporting in, we’re getting indication of how often people visit these sites. If it turns out that when we do periodic reassessments and it looks like the sites are being degraded, we can go to our sanctuary advisory council and ask them to convene a working group made up of the public, the folks diving out there. It will be comprised of those people who are calling in. Not only will we know the level of use on each site, but we also know who is going out there so we can communicate with these folks. The purpose of this is not to be restrictive, it’s a mechanism by which we can monitor these sites. If there is an indication there is a problem we can form a working group and rally the interested parties. We will say “Here are the findings we have, our concerns, now what do you guys think we should do about it?” We’re not going to know who is out there if they don’t tell us they’re out there. We’re not going to know if there is degradation due to a site’s over-use or a result of environmental deterioration. The national parks service does it all the time. They call it “limits of acceptable change”. What they do is monitor use. If it turns out the area is getting a lot of use they take a step back. They assess whether what they are doing is the best way to protect a site for long term. It’s hard to argue against doing that if it’s not a hard reporting burden on the diver. It’s putting them in closer communication with the sanctuary. It’s actually developing a relationship with us. Then we can go to them when there is a problem on the wrecks so that they can continue to enjoy diving there. Joe – So you saying instead of being restrictive it brings the diving community to be part of the solution and part of protecting the site? Craig - We’re really looking to partner with the diving community and build them into the management process. Joe - I think it’s just a misunderstanding of fear. If it turns out to be that way then I think that’s a great thing. It’s a resource for all us. OK, that’s the notification. What about concessionary program? What’s that all about and why? Craig - Actually Joe, that’s something we’re still chewing on. Like I said before the action part of the working group is to produce advice. It’s when we’re really considering all the recommendations, but there are some of them we have to rethink. And that’s one of them. We’re not quite sure where NOAA’s going to fall on that. I don’t think we’ve fully evaluated it internally. Joe - If it were to go that way, what is the benefit of doing that? Why would you want to go that way? Craig - Well, what came up in the discussions of the working group is that the sanctuary can’t be looking over everybody’s shoulders all the time to see if people are anchoring over a wreck and diving on it. Having a concessionaire who was responsible for any damage to the wreck that might have occurred by the divers was one of the underlying considerations. In other words, if we’re authorizing a commercial operator to take people there, how can the sanctuary gain some oversight and essentially apply some responsibility on the part of the operator so if damage is done to the sanctuary resource that person would be ultimately responsible. That was part of the discussion leading up to that recommendation. Joe - It just seems to me that if you have the notification part of the program in place then this a little over-kill. Craig - I think the concessionaire model was only for accessing sites that were heritage preserves. At this point we’re only looking at one or two sites. Actually two. You’ll see it in the Action Plan that the Frank A.Palmer and Louise B.Crary and the Portland sites be considered reserved as preserved status. Joe - What determines historically significant? Craig – There are two authorities that we rely on to provide guidance on these. One of these is the National Marine Sanctuaries Act. When I have to deal with the various authorities I have to keep going back and forth. The definition of historical resource under the sanctuary program regulations is kind of lengthy. It includes sites, structures, objects which are associated or representative with people or cultures like the case of the Portland, which was the premier what they called a nightboat on the New England coast. It was palatial by standards of the day. It was essentially like the Titanic of New England. Not only because it sank, but because it was such a grand vessel. It was crucial to commerce between Boston and Portland, ME. It has deep roots in Portland as well in Boston. The shipwreck is in such good shape, I would use the term museum quality. It’s very special and it has the very significant role that it served in history and is representative of a type and class vessel that is no longer around. The Frank A.Palmer and the Louise B.Crary were coal schooners you heard about. They served the coal trade from Virginia up to New England. They are two of the largest of their class of vessel. The longest four-masted coal schooner ever built and one of the largest five-masted schooners. They are in remarkably good shape. Their masts, everything is still there. Again they are representative of essentially the peak period of a two-decade point in history where these vessels were being built in Maine. They operated to supply energy to Boston. So they appeared in a time where there’s a particular historic event that is associated with them and they are in very good shape. So the term significance has a number of ramifications. Under the National Historic Preservation Act, which the National Marine Sanctuaries Act ascribes to follow, it says that the site must be generally 50 years of age and again associated with and has made significant contribution to making history. That’s where the significance comes in. The significance is actually a term of the historical research. Joe - Would a wreck like that be in an exclusion zone where a diver would not be able to get a permit to dive on it? Craig - It would be historic preserve status. It looks like those two categories of vessels would qualify for preserve status, but not all coal schooners for example would. One of the other one’s we’re looking at that we also know divers are accessing is the Paul Palmer. We’re doing a fair amount of work on that one. It’s also a coal carrying schooner of that period, four or five masts. It’s in relatively shallow water. It’s taken the brunt of storms and being hit with fishing gear. So that will be open to the public and I think that will be a very exciting dive site. But we wouldn’t consider that for preserve status. It would be a historic site that would be made public. Virtually all of the others that we looked at to date, all indications are that we will be identifying them as “Public Access” dive sites. We don’t see the historic preserve designation being widespread. Joe - That’s good information. Obviously that is information that we didn’t have before. Craig - You know if next year they find a Basque vessel or a Viking ship then all of a sudden something would pop up. That would be historically significant. Joe – Sure, I understand. This is just a snap-shop in time. OK, I think we’re pretty much getting to the end here. Could we go back to the Thunder Bay? Craig - The major difference between Thunder Bay and the Stellwagen are we both have historic shipwrecks that cover a couple of periods. But the big difference is the wrecks we are looking at now for historic status are deep. They’re more than 300ft deep. The current around the sanctuary are very strong. We have strong tidal currents and we even have things called “internal waves” that pass through the sanctuary. It’s a very confused oceanographic area. On some days it’s very calm out there and then other days it can be quite rough. But even on the calm days the tide can be strong and existing sanctuary regulations prevent you from grappling or tying up to wrecks. These vessels are very fragile, relatively intact, but fragile. We know that from the investigations we have been doing with the ROV’s. So to have someone anchor a boat at depths of 300 feet or more you’ve got a 7 to 1 scope, a couple thousand feet a line and a boat that’s 30ft or more on the surface and very strong currents working against that line. Where’s that anchor going to go when you drop it? Under those strong circumstances you want to get as close to the wreck as possible. We can’t have people dropping anchors that go plummeting through the floorboards or crush china. The differences from Thunder Bay are you have much greater depth that makes anchoring very difficult. You have very strong currents that if the anchor was on the wreck it could do a fair amount of damage. For the discussions, the manager of the Thunder Bay sanctuary was actually one of technical advisors of the working group. So he was a party to all of the discussions that led to the Action Plan that was produced by the working group. Joe - Is there a way that interested people can subscribe to an email list or do they just send an email saying look I’d like to know when the proposed Management Plan is available for review? Craig - Right now they should just send an email. We are in the process of setting up an email notification, but I don’t know the status. We’re not set up and we’re waiting for a clearance from headquarters. The person I need to talk to is back at headquarters. The point is everything up to now is the advice we have been given. So everything that your constituents, the technical divers have been reading has been something that has been prepared by the public as advice to NOAA. Now what NOAA is doing is drafting the Management Plan that they think would provide the level of protection required. That’s when we want people to say “yes we agree” or “don’t agree” and why. That’s when they will have 60 to 90 days to provide comment. We’re also planning on running public meetings so people will be able to discuss with us, not just sending in their comments. That’s the main thing. Joe - I hear you loud and clear. I appreciate you taking the time not just for the call today but to take the initiative behind the scenes after our first discussion to go up through the chain of command so I could have this interview. Because as we discussed before, how we end up on the other side of this issue will help determine how our two groups work together in the future. Hopefully, we all want to make sure we’re working together as a team going forward. I feel better after talking with you this time about some of the comments you made that you couldn’t discuss before. It sounds like there is a concern. Protection is first and foremost and we all understand that. Beyond that it’s making sure (it sounds like) that the resource is accessible with the exception of those for the reasons that you mentioned, yet monitored. For the well being not just for the site but for all of us to be able to enjoy for posterity.
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Date placed: Feburary 17, 2006 Click below to download a letter from NOAA to WDM in response to diver's concerns regarding the proposed Action Plan for Stellwagen National Marine Sanctuary. Click here for PDF download |
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