The Stellwagen Bank National Marine Sanctuary (SBNMS) is currently in the process of revising its management plan, the first such revision since the original plan was put in place back in 1993. Such revisions are required periodically by Congress.

Whereas the original plan made no mention of diving, basically restricting divers only from taking, or attempting to take, artifacts, the proposed plan would declare some wrecks within the sanctuary off-limits. Access to other wrecks would be left open. Newly discovered wrecks would be considered off-limits until they could be studied and placed in one category or the other. And divers would be required to notify the sanctuary before diving in it.

At first glance, the proposed plan seems restrictive, particularly the designating of some wrecks as off-limits. "In principle, I am not opposed to protecting some wrecks -- with the caveat that we need to define 'protection' further," says Heather Knowles of Northern Atlantic Dive Expeditions, a group that has posted a petition against the proposed plan on its website www.shipwreckdivers.org. "I am opposed to it in this case because of the ambiguous, vague and subjective criteria that will be used to define which wrecks should fall into this category."

That criteria seems to be potential eligibility on the National Register of Historic Sites. "What we're trying to do is find a balance between protecting wreck sites that have historic value and providing access to divers," says Craig MacDonald, superintendent of the SBNMS. "I don't believe many wrecks would fall into the restricted category. The majority would end up in the open-access category. A lot of sites, though, are very deep and we're at a point technologically where we can actually do live web feeds from them for large audiences when we send ROVs down. And we'd like this audience to have the chance to see them undisturbed."

The issue of newly discovered wrecks being restricted until they can be studied seems less contentious. "There are a lot of shipwrecks out there that people don't know about," says MacDonald. "So what we're saying is, when we find one, give us time to assess the site and put adequate protection measures in place. It's more likely than not that it will become a public-access site."

At the same time, though, Knowles points out that there is no time frame built into the system, allowing wrecks to languish in the discovery phase potentially forever.

As for mandatory notification, "We don't mean to suggest anything Draconian here," says MacDonald. "We'd just like a simple phone message to our office saying that you're going to dive. That way we can begin to figure visitation rates. If a site then begins to degrade, we could make a realistic evaluation of whether the cause is environmental or not, and then ask the public what they want us to do with the site."

Some divers, however, worry that sanctuary staff could use the information to make surprise visits to sites, breeding an air of distrust. "If their purpose is to collect this information for determining site usage," says Knowles, "then it shouldn't matter if the information comes in after the visit." Knowles also points out that post-visit notification might be more accurate since it would eliminate the possibility of counting dives that were actually never made due to weather or plan changes.

I've checked the regulations pertaining to divers at three other national marine sanctuaries (randomly chosen), the Florida Keys, the Channel Islands and the Thunder Bay National Marine Sanctuaries, and found them all to be less restrictive. Each has more known, diveable wrecks, but restricts access to none. Nor do they require notification prior to or after diving. Their only restrictions, beyond forbidding the removal, or attempt to remove, artifacts, is on secondary activities, such as spearfishing. In fact, the Channel Islands Sanctuary is in the process of also re-working its management plan and the staff there foresees no changes pertaining to divers.

In my opinion, part of the problem here is that the sanctuary has historically done little for divers (or against them, for that matter) and consequently has no history or track record with us. Case in point, I've yet to meet a single diver who attended or even knew about the numerous public meetings at which this plan was discussed, even though they took place from Mystic, CT to Portland, ME and generated something in the range of 20,000 public comments (the overwhelming majority of which had nothing to do with diving).

Obviously there was no attempt on the sanctuary's part to keep us in the dark, they just don't know enough about us to know how to reach us. That's not good. Further case in point: look at the websites of the three sanctuaries mentioned above. They all burst with information on the dive sites within them -- locations, descriptions, photos. The same cannot be said for the SBNMS website.

From my discussions with MacDonald, I believe him when he says that they want to welcome divers into the sanctuary. My own opinion of the proposed plan is that none of us can know whether it's going to be fine or a piece of crap until NOAA comes out with its own draft, probably in the spring of 2006. Until then, there's no way to know the exact wording or details -- and that's where the devil may or may not be.

Here's what I'd like to see, though. If the new plan places any restrictions on diving beyond those already in force, their each and every nuance should be spelled out. Some wrecks may be restricted? Fine. But tell us beforehand exactly the basis on which those decisions will be made. The fact that other sanctuaries have no restricted-access sites should also be factored into the decision-making process. Leaving a provision for divers to request permits to dive restricted wrecks would also be a good thing. As for newly discovered wrecks, I see no way to codify how long a site could be held in abeyance until a decision is made on it. In fact, none of the other sanctuaries mentioned above have such a restriction. And to the best of my knowledge, divers are not complaining that sites in these sanctuaries are being sat on. As for mandatory notification, my gut feeling is that the information will be used solely to determine usage rates. That strikes me as a common sense approach to management, even if other sanctuaries don't require it. If, however, forms or paperwork are introduced into the process, I would have to view that as an intentional roadblock/obstacle.

With regard to the lack of a relationship the sanctuary has with divers, they've mentioned the possibility of placing mooring buoys at some wrecks so that dive boats don't drop anchor on top of them. This would be a huge step forward -- not just to protect the wrecks but to act as a welcome sign. The same could be said for including more dive information (or any, for that matter) on the sanctuary's website. After seeing the websites of the other sanctuaries, I cannot wait to visit and dive them. We should get the same feeling from the SBNMS website. I'd also suggest they leave up video footage of the wrecks to be accessed at any time, not just during live feeds.

The benefits of such actions would extend not just to divers but to the sanctuary itself. My own experience with the Lake Champlain Underwater Preserve, where divers are clearly welcomed, is that local divers take pride in the wrecks and are protective of them. In other words, an active, engaged constituency that can spend many more man-hours on the wrecks than the sanctuary's staff, would be a good thing for them. On another note, some wrecks in other sanctuaries lie well in excess of traditional recreational depth limits, and yet the staffs at these sanctuaries express no concerns with respect to accident liability. That's a refreshing approach.

Our plan here at Blue Sphere Pubs is to revisit this issue when the NOAA draft management plan comes out -- again, probably sometime in the spring of 2006. At that time, there will be at least a 30-day review period (that may actually be extended to 60-90 days) and we will take a firm position on it one way or the other. We will also encourage everyone else to not only do the same, but to express their views strongly in the appropriate forum.

Jerry Shine

For a complete copy of Heather Knowles' and David Caldwell's letter arguing against the proposed plan, click here.