Below is a summary of public comments received on the final reports and recommendations of the Massachusetts Ocean Management Task Force. Also see Comments on the Draft Principles and Preliminary Recommendations.

Maritime Trades Council - Gerard Dhooge, President

- Any changes must be prospective only and not interfere with projects currently undergoing regulatory review/ Cape Wind; NEPA review process is stringent enough
- Any addition to existing protected areas must be balanced against maritime usage; Consider social and commercial value of maritime uses when considering MPAs or expanded sanctuaries; current federal and state regulations (especially OSA) are adequate
- Report should strengthen its support of renewable energy; while report supports renewable energy, must remember limitations presented by existing regulatory framework; OMTF should not advocate any legislation contrary to 1997 renewable portfolio standard legislation (which projects like Cape Wind would help fulfill)
- Environmental Justice must be stressed—need to balance recreational uses of ocean with necessity to improve air quality

The Nature Conservancy - Wayne Klockner, State Director

- MA Chapter is identifying ecologically significant areas in nearshore waters of Northeast Atlantic Coast
- Supports efforts to improve regulatory framework to one that is proactive and comprehensive
- Applauds notion that MA citizens need ocean stewardship ethic

The Woods Hole Research Center - George M. Woodwell, Director

- Commends Task Force for much more mature and constructive product than available originally
- Pleased document is no longer biased against development of wind energy
- Fossil fuel plants warm coastal waters and have other deleterious effects—emitting carbon dioxide and other contaminants
- Need to state that coastal zone will be used in various ways to alleviate climate change problems

Oceans Public Trust Initiative (Project of Earth Island Institute) - Cindy Lowry, Director

- Disappointed with final recommendations; no bold initiatives or steps to implementations laid out; criticizes omission of offshore wind energy facility issue
- State permitting process flawed; State is passive in accepting procedure forced upon by Army Corps
- Suggest that stronger laws be enacted to protect the public trust; no projects approved in interim
- Suggests OMTF follow US Ocean Commission report and state clear need for new program to protect ocean public trust resources

The Ocean Conservancy - John Phillips, New England Regional Director

- Support Guiding Principles and similarity to those of US Commission on Ocean Policy
- Sees CORMA as new model; emphasizes establishment of clear authority and coordination among agencies and availability of citizen suits
- Support MPAs and revision of Ocean Sanctuaries Act, but recommends these changes occur together, in consideration of broader reform efforts
- Suggestions on potential MPA process: 1) working group efforts should consider needs of all coastal and marine protected areas, not just Ocean Sanctuaries, as well as designation of future MPAs, 2) MPAs should be incorporated into CORMA for smooth integration and 3) working group and/or stakeholder group(s) should have clear purpose integrating science, adequate time/resources, defined role within agency and legislative actions and appropriate stakeholder representation
- Ocean Management Coordination - MA should develop regional pilot projects in Gulf of Maine utilizing ecosystem based management
- Support Resource Trends Advisory Group and urge them to develop scientific goals, rather than management goals; should consider ecosystem health and biodiversity, rather than just fishery management stock assessments
- Support Ocean Literacy and Stewardship
- Support evaluation of Ch. 91 tideland fees and urge consideration to keep concept of rents, royalties or fees open to apply to new or evolving issues that currently do not fall under Ch. 91

Clean Power Now - James Liedell, Operations Director

- Since report has been unanimously endorsed by the Task Force, it should have broad political support
- Encouraged that the Cape Wind proposal will not be delayed
- Concern over aesthetics and NSWF is only factual opposition
- Strong support for offshore wind

Competitive Power Coalition of New England, Inc. - Neal Costello, General Counsel

- Concerned of conflict with 1997 legislation for renewable energy standards
- Happy to see that recommendations will not affect Cape Wind

Cape Cod Commission - Margo Fenn, Executive Director (staff only, Commission has yet to formally review)

- Need to address land based activities in relation to coastal area—infrastructure development, transportation improvements
- Support CORMA, yet concerned about local concerns being met in state-wide effort
- OSA—agree that needs to be simplified and bearing on permitting agencies needs to be clarified
     - consider relation of OSA to provisions of Chapter 91 for the licensing of structures on tidelands, is public interest adequately represented in administrating use of tidelands?
     - Support concept of instilling the Act with a "public interest and need" similar to that in the original statute
- Before MPAs designated, should establish better system for coordinating other existing designations and promote a more economically diverse marine environment
- Consider visual, cultural and aesthetic impacts; determine procedures for assessing cumulative and secondary impacts of permitted activities
- Overall, need more resources for local planning

Massachusetts Board of Underwater Archaeological Resources (BUAR) - Victor Mastone, Director

- BUAR requests to be included in interagency working group for the planning and implementation of CORMA
- Reminds that BUAR is the sole trustee of the Commonwealth's underwater heritage and is charged with encouraging the discovery and reporting, as well as the preservation and protection, of underwater archaeological resources (Ch. 6, Sections 179-180; Ch. 91, Section 63)
- BUAR can already designate underwater archaeological preserves and should have been included in MPA section (Ch.91, Section 63 and 312 CMR 2.15 (3)); federal Abandoned Shipwreck Act (PL 100-298) states that public access to shipwrecks for recreational purposes must be guaranteed
- Use Characterization—urges inclusion of recreational diving community as resource user group, represented by the Bay State Council of Divers
- Encourages understanding of ocean issues by citizens, yet is concerned about legislation that would provide unrestricted public access to archaeological site files (as location confidentiality plays major role in site protection)
- Disappointed with Technical Report—lacks cultural context (exploration, settlement, transportation); "cultural resources" not adequately addressed and remain undefined in Glossary

Conservation Law Foundation - Priscilla Brooks, Director - Marine Resources Project

- CORMA of paramount importance
- MPA effort should be parallel to CORMA
- Urge state agencies to consider climate change impacts as a core factor in the permitting process of any ocean development activity
- Urge immediate comprehensive ocean monitoring and research plan for all Commonwealth marine waters and the full range of marine life
- Encourage establishment of dedicated ocean management account through Ch. 91 revenues

Alliance to Protect Nantucket Sound - Susan Nickerson, Executive Director

- Take clear and direct action to resolve schism between state and federal interests in Nantucket Sound
- Establish state jurisdiction over the central portion of Nantucket Sound
- Prohibit or severely restrict non water-dependent activities in state designated coastal zone areas
- Define "projects in the pipeline"
- Suspend review of Cape Wind until CORMA in place
- Immediately add Nantucket Sound to list of federal MPAs
- Suggested CORMA language—incorporating OSA language, list of allowable uses, language on public trust protections
- Update MA CZM Plan
- Protect traditional uses of offshore waters to benefit public interest (i.e. fishing)
- Supports an institutional role (although undefined) for DMF in implementation of CORMA, as well as employment of collaborative research to guide decisions on fisheries management
- Consider energy conservation and efficiency in climate change
- Alliance formally requests seat at the table for interagency working group formulating the components of CORMA

Alliance to Protect Nantucket Sound form letter submitted by: Geoff Dickes, Oak Bluffs; Robert diCurcio, Nantucket; Janet Rogers, Hyannis; William Gillit; David & Meg Nauss, Hyannis Port; Susan Scolles, W. Yarmouth; John & Dorothy De Young, Hyannis; Katherine Scott

- Establish state jurisdiction over central portion of Nantucket Sound
- Prohibit or severely restrict non-water dependent activities in state-controlled waters
- Suspend all proposed development including the Cape Wind project until there is a comprehensive process for reviewing these proposals
- Prohibit activities in federal waters that would be prohibited in state waters and protect traditional uses such as fishing within the proposed CORMA
- Add Nantucket Sound to the federal list of MPAs
- Emphasize energy conservation as part of a greater effort to address climate change
- Ask that Alliance be given formal seat at table of working group that will be drafting CORMA

Massachusetts Fishermen's Partnership

- Legislature should give DMF and CZM a vote in DEP licensing/permitting procedure and power specifically to protect interest of marine fisheries and fishermen in tidelands
- Permitting process should be designed to ensure the adequate protection of existing public access (including authorized fishing rights) and of marine fisheries resources and habitats located in tidelands
- Permits should not be issued for proposed activities or uses unless it has been demonstrated that every effort possible has been made to offer greatest public access and greatest extent of mitigation possible of any potentially harmful impacts to marine fisheries, their habitats or current uses under the specific circumstances
- Permitting decisions should be based on statistically significant, adequate and measurable scientific data derived from processes conducted and/or overseen by the public agency responsible for making the permitting decisions; never based solely on data provided by applicant
- In cases where greater public welfare is deemed higher priority than activities, mitigation fund should provide direct compensation to impacted fishery; should provide direct compensation to impacted commercial fishermen and/or provide research funding to prevent or mitigate impacts

E2 Environmental Entrepreneurs

- Support CORMA, but want to make sure interagency body is free from political influence and will not be used to pre-judge specific proposals without considering each on its merits; strongly recommend legislation not apply retroactively to projects already under construction
- Support MPAs
- Nonpoint source pollution (mercury, fossil fuel runoffs, industrial toxic wastes, nutrient pollution) issue was major omission from report

Massachusetts Marine Fisheries Commission - Mark Weissman

- In most respects, Commonwealth was well served by report, but why wasn't Cape Wind addressed?—urge to address it in implementation
- Wind project endangers Nantucket Sound's marine resources, the extensive commercial and recreational fishing activities they support, and the essential fish habitat
- Formally notified Corps of concerns in August 2002, citing Magnuson Act sections allowing the Commonwealth the direct authority from Congress to manage fisheries resources and habitat in Nantucket Sound
- Urge moratorium on development in Nantucket Sound until legitimate state and federal management occurs
- Urge DMF experts to be brought to forefront of any future evaluation process

Cape Wind - Dennis Duffy, Vice President of Regulatory Affairs

- Cape Wind in federal waters
- Report is properly limited to prospective application
- Premature to endorse CORMA—not sufficiently defined or justified
- Report does not quantify additional costs needed to implement suggested new programs
- Report based largely on misstatement of the Massachusetts Public Trust Doctrine (does not create any presumption or provide any rationale against private uses of submerged lands that (i) fulfill a legitimate public purpose and (ii) provide a greater public benefit than public detriment).

James Rossignol

- All boaters should be licensed with certificates of boating safety

Michael Jacobs - Concord, MA

- Glad to see that their previous comments on global warming/ocean level rise and fossil-fired power plants were addressed in final draft
- Hopes legislative efforts will recognize the complexities of threats to oceans and the multiple citizen interests, as the Task Force did

John Paone - Mashpee, MA

- If ocean is developed for private gain, than it is difficult to perceive that anything will be exempt from commercial development
- Commonwealth needs to be more assertive with Federal government and insist that Nantucket Sound have higher levels of protection

Richard Mullin, Dennis, MA

- Cites statistics and reasons why Horseshoe Shoal is inappropriate location for wind energy and negatives to wind development in general
- Make Nantucket Sound a National Marine Sanctuary

Donald Pryor - Brown University, Chair Nutrient and Bacteria Pollution Panel for Governor Carcieri's Narragansett Bay and Watershed Planning Commission

- Report overlooks MA's stake in Narragansett Bay both in map coverage and text
- Encouraged by interstate agreement discussions
- Report omitted water quality issues and was schizophrenic on water quality--included in monitoring but not governance, etc.; hopes water quality and other ocean issues will be brought closer together, not further apart
- Improving public access and restoring degraded habitat received less attention than expected

Massachusetts Lobstermen's Association, Inc. - Bernie Feeney, President

- Overall support for Task Force work, but remind to consider how projects may have adverse economic impacts on fishermen
- Encouraged by recommendation that existing fishery regulatory process will remain with DMF; oppose any closure that is not part of a fishery management plan
- Components of CORMA could complicate process already managed by DMF and Marine Fisheries Advisory Commission, as experts in the field; CORMA could make process less efficient
- Leave all marine fisheries management out of CORMA
- DMF should have more influence on project decisions that may affect marine resources
- Support marine protected areas only if will include fishing operations as protected elements
- For MPAs, do not support having DMF as one member of larger working group (they should be the only entity with closure authority for fishery management reasons)

Samuel Bennet - Counsel, Department of Environmental Protection, Boston

- Impressive report—encourages working with Legislature for continuity with future administrations

Jake Dewey - Hyannis Port, MA

- Prevent any permanent commercialization of Nantucket Sound

Willie Goldwasser - Newton, MA

- Hard to believe elected officials or state departments have no say over Nantucket Sound activities

M. Sforza - Waltham, MA

- Strongly against wind farm

Rhoda Staley - S. Orleans, MA

- Against wind farms; Denmark's were a disaster

Don Hayward - Monument Beach, MA

- Supportive of wind farm in place of fossil fuel energy

Nola Assad

- Against wind farm; Nantucket Sound is a treasure

Healthlink - Jody Howard, Board of Directors

- Applauds report and supports prospective nature of report not impacting projects currently under permitting review
- Supports inclusion of Climate Change Plan recommendation and beneficial impact of offshore renewable energy projects
- Technical Report correctly notes thermal discharge impacts of conventional power plants
- Can be strengthened by including an enumeration of negative impacts to MA coastal waters from conventional power plants