STEALTH SANCTUARY: THE CHALLENGE OF PROTECTION AT STELLWAGEN BANK NATIONAL MARINE SANCTUARY

Centuries of exploitation in marine areas have negatively impacted the biomass, diversity, and function of marine habitats and life on a global scale. Marine protected areas (MPAs) are increasingly relied upon as a conservation strategy to address the degradation of marine resources in the U.S., but research on the social context that shapes protection of these marine spaces remains sparse. This study explores protection through the evolution of the people and groups who use the marine resources within MPAs and those who manage MPAs over time. Stellwagen Bank National Marine Sanctuary (SBNMS) is used as a case study to understand how roles and relationships among these may or may not influence MPA management decisions and policy. Data was collected through thirteen semi-structured interviews conducted in the summer and fall of 2019 with individuals who have historic and/or current ties to the use and management of SBNMS, participant observation as a SBNMS intern during the summer of 2019, and document analysis of the management plan and relevant legislation. Finding indicate that SBNMS is faced with multiple challenges related to the federal legislation that governs sanctuaries, dominant regional histories of resource use, and intra-institutional communication in its efforts to enact long-term protection for Stellwagen Bank. Additionally, this site provides valuable insights into how people involved with management at Stellwagen perceive protection of marine space and offers opportunities to reconceptualize protection as a multi-faceted endeavor that includes non-ecological elements such as education and outreach. Results from this research have tangible applications for SBNMS but may also serve as a starting point to evaluate protection definitions and priorities for other regional MPA institutions.


LIST OF TABLES
People on the top deck of the boat eagerly pressed against the railing, jostling for camera position, eyes continuously scanning the horizon in search of a small disruption in the deep blue surface of the Atlantic that could signify a whale. Only minutes ago the naturalist on board had announced our arrival at Stellwagen Bank, officially known as Stellwagen Bank National Marine Sanctuary (Sanctuary or SBNMS). This area is wellknown as a seasonal feeding ground for humpback whales. We did not have to wait long before a small group of humpbacks came up for a breath nearby, the white on their pectoral fins glowing green in the phytoplankton rich waters. As our boat slowly turned to move alongside the group, mimicking the whales' direction and pace, a small speed boat, perhaps people on a day trip from Provincetown, began approaching the whales head on. As we watched the boat get steadily closer, the naturalist from our boat called out over the speaker system to the other captain. They calmly asked the boat to reduce their speed and approach from the side. After a few repeated warnings, the naturalist's tone became more urgent and angry, and their voice reverberated out across the water.
Soon multiple tourists from our boat began shouting at the smaller vessel to turn around, with one person even holding up two middle fingers. Within moments the tone of the tour had transformed from sheer awe at the first sight of whales to defensive towards those who might harm them.
The small boat ultimately stopped before doing any immediate harm and reversed course to the recommended distance of 100+ ft. (Whale SENSE 2020), but the tension of this moment sparked a larger conversation aboard the whale watch tour where I was doing passenger surveys for the day. As we left that group of whales and people shuffled back to their seats, someone asked about the rules protecting whales in the Sanctuary. The term MPA is used frequently in discussions about tools for marine conservation, but there is no singular definition of an MPA or the purpose of an MPA (Agardy et al. 2003, Baur et al. 2013. Discourse around what qualifies as an MPA and the normative goals of MPAs are often dominated by ecological factors despite a growing body of research that suggests critical links between social success and the sustainability and effectiveness of MPA projects (Christie 2004, Dalton 2005, Morin 2001, Pomeroy et al. 2007, Singleton 2009, Wahle et al. 2003. Because of the multiplicity of understandings about MPA definitions and objectives, exploring the histories of SBNMS and the social context of the Sanctuary's management will help illuminate current challenges and opportunities for managers and people who use this Sanctuary space.

MPA Definitions and Development
Increasing demand for marine resources often results in not only overexploitation but also opportunities for escalation of conflict over how uses are prioritized in marine spaces (Inniss et al. 2017, Jackson et al. 2001. While marine management strategies have historically been enacted through sectoral regulation, the development of the United Nations Convention on the Law of the Sea (UNCLOS) and the passage of the Magnuson Stevens Act in the late 1970s marked the beginning of a slow shift towards coordinated, multi-sectoral management designed to mitigate the diverse demands on marine resources (Cowan et al. 2012). There are many methods that seek to manage resources through the regulation of marine space, but MPAs are often discussed as key conservation frameworks to aid in the development of multi-sectoral management (Caveen et al. 2014, Mahajan andDaw 2016). MPAs are also increasingly viewed as a means of climate change adaptation and economic development (Fox et al. 2012).
Definitions of what constitutes an MPA vary widely depending on context (Baur et al. 2013, Caveen et al. 2014, Dudley 2008, with some authors even arguing that the lack of a precise definition is detrimental to coordinated conservation efforts (Costello and Ballantine 2015). Despite this, MPAs can be generally understood as a form of spatial management that regulates human behavior within a designated marine zone through a series of rules. Much like terrestrial protected areas, MPAs may completely or partially exclude access for certain activities through a mixture of no-take (no extractive uses) and/or multi-use zoning. The actual level of protection for marine resources ranges from marine reserves, a specific subset of MPAs that prohibit all forms of extractive use, to multi-use zones with only minimal protection against dumping or extractive use (Baur et al. 2013, Caveen et al. 2014, NCEAS 2001. MPAs may also be created with specific goals in mind such as protection of an important marine feature or preservation of cultural heritage through artifacts, sites, or activity. The U.S. currently defines an MPA as "any area of the marine environment that has been reserved by Federal, State, territorial, tribal, or local laws or regulations to provide lasting protection for part or all of the natural or cultural resources therein" (US Executive Order 13158 2000). According to the International Union for Conservation of Nature (IUCN), a protected area is, "A clearly defined geographical space, recognised, dedicated and managed, through legal or other effective means, to achieve the long-term conservation of nature with associated ecosystem services and cultural values" (IUCN 2020). While these statements have some overlap, the international definition specifically mentions management and prioritizes conservation of nature with cultural values as secondary.
Both definitions emphasize the need for lasting, or long-term, protection of resources. The IUCN additionally created six categories for protected areas (both terrestrial and marine) to facilitate communication across varying countries, agencies, and institutions (Table 1) (Dudley 2008). While both the U.S. and the IUCN acknowledge the context dependent nature of MPA development, these definitions are frequently used as reference points for understanding what qualifies as an MPA.  (Dudley 2008).

Protected Area Category Description
Ia. Strict Nature Reserve Area set aside to protect biodiversity and/or other important geological features with strict limitations for human access. May serve as biological reference areas.
Ib. Wilderness Area Strongly protected areas with limited human modification. Intended to represent and preserve an area in its natural condition.
II. National Park Areas designed to protect large-scale landscapes and natural processes with carefully managed vistorship.

III. Natural Monument
Areas created to protect a specific natural feature such as a cave, sea mount, or even a historic grove of trees. These areas are typically smaller as they are tied to a feature rather than landscape.

IV. Habitat/ Species Management
Areas set aside to protect important species and/or their habitat. Research and other management activities may take place, as needed.

V. Protected Landscape/ Seascape
Areas designed to safeguard valuable human and nature interactions that have developed over time tied to particular spaces on land or sea. Applies to areas that have historic long-term human use.

VI. Protected Area with Sustainable Use of Natural Resources
Areas designated to protect natural landscapes/seascapes and sustainable resource use or low-level non-industrial resource use.
Overfishing and the prevention of overfishing has been a driving force in MPA development, and MPAs are commonly portrayed as an alternative to the perceived failures of conventional fisheries management techniques (Baur et al. 2013, Bohnsack et al. 2004, Caveen et al. 2014, Guénette et al. 1998, Murawski et al. 2005, Pomeroy et al. 2007). MPA projects also represent efforts to shift conservation policy away from species-specific measures towards an ecosystem level approach (Dell'Apa et al. 2015, Douvere 2008, Halpern et al. 2010. While conventional management strategies such as closed seasons, catch limits, gear restrictions, and effort limits have the potential to protect habitat, non-target species, and non-ecological values, MPAs, in theory, make these protections more explicit and consistent. By managing a space holistically, species, structures, and interactions that are not directly emphasized in a management plan can also receive the benefits of that management plan through overlap in location (Caveen et al. 2014, Gell and Roberts 2003, Inniss et al. 2017, Sala and Giakoumi 2018. In addition to indirect benefits for non-target resources, MPAs can also be framed as opportunities to reduce costs in administration and enforcement that can occur in single-species management plans (Berghöfer et al. 2008, Johannes 1998, Halpern et al. 2010.

Protection in the U.S. Context
MPAs are not a new form of marine resource management. For instance, authors such as Johannes (1978) argue that nearly every method employed by modern fisheries managers, including closed areas (MPAs), has been in use for hundreds of years, if not longer, in some form by fishers in the tropical Pacific Ocean. However, in the (settler colonial) U.S., MPAs such as scientific research reserves have been sporadically established since the 1920s, although they first received major attention by academic researchers and policy-makers in the U.S. as the result of Beverton and Holt's 1957 paper on fish population dynamics (Beverton and Holt 1957, Guénette et al.1998, National Research Council 2001. In contrast to this more recent MPA movement that began in the mid to late 1900s, spatial management efforts in the late 1800s and early 1900s were often seasonal and/or rarely included full fishing restrictions (Bohnsack et al. 2004 Commission, fueled by both a budding academic interest and a political desire to prepare and respond to political changes of the era, produced a final report in 1969, "Our Nation and the Sea: A Plan for National Action," that called for concrete congressional action (Scheiber 1998). This report, along with high profile environmental catastrophes such as the 1967 grounding of the Torrey Canyon and a major oil spill off of the coast of California in 1969 helped spur a number of domestic environmental laws in the early 1970s (Chandler 2006, Scheiber 1998).
The national marine sanctuary system was created in 1972 with the passage of the Marine Protection, Research, and Sanctuaries Act of 1972 (now the National Marine Sanctuaries Act, NMSA), a law strongly focused on the prevention of dumping and industrial development (Chandler 2006). Although there are other forms of MPAs within U.S. waters, the national marine sanctuary (NMS) system is one of the most prominent attempts to protect "nationally significant areas in the ocean and Great Lakes" from degradation (Sarri 2018). The NMSA has been reauthorized six times since its initial creation with the most recent reauthorization occuring in 2000 (NOAA 2020). Of the ocean within the U.S. Exclusive Economic Zone, approximately 0.5% is protected through the NMS system, although the level and effectiveness of protection are contested (Borrelli 2009).
There are a total of fourteen sanctuaries and two national monuments managed by the Office of National Marine Sanctuaries (ONMS) under the umbrella of the National Oceanic and Atmospheric Administration (NOAA). This office, in turn delegates management of a sanctuary to the sanctuary staff who receive non-binding recommendations from the Sanctuary Advisory Council (SAC). The sanctuary staff, with guidance from the SAC, are tasked with comprehensively managing a given space for the long-term protection of natural and cultural resources, promoting public awareness of issues in the marine environment, and working "to facilitate to the extent compatible with the primary objective of resource protection, all public and private uses of the resources of these marine areas not prohibited pursuant to other authorities" (NMSA 2000). Each individual sanctuary is additionally expected to facilitate cooperative research and create policies responsive to new research (ONMS 2010).
Although management of marine spaces that balances the needs of many groups is generally compatible with the goals of other MPA projects nationally and internationally, the framing and implementation of the NMSA is a source of frequent debate in U.S.
While there are some hopeful perspectives on the NMSA, such as Baur et al. 2013, who argues that the NMSA is unique, and thus powerful, in its mandate for place-based rather than sectoral management, the NMSA is generally viewed as underdeveloped in application and chronically underfunded (Owen 2002, Reeves 2000. In particular, the NMSA is criticized for failing to provide the legal clarity of purpose and tools needed to carry out its original goal of meaningful protection of marine resources (Brax 2002, Chandler 2006, Owen 2002, Reeves 2000, Sutherland 2008, Weber 1988, 1997. Despite this, the NMS system is still referenced as the central example of U.S. MPA development (Reeves 2000, De Santo 2013.

Islands of Protection
Controversy regarding the effectiveness of the NMSA is largely related to language and the broader debate around the effectiveness of varying levels of ecological protection. Since the early efforts to create MPAs in the U.S., questions about the legislative boundaries of proposed ocean protections have been prominent. Initial hopes for marine reserves to become spaces similar to national parks and comparisons of the NMSA to the Wilderness Act of 1964 ultimately shifted to support for sustainable, multi-use zones and an Act that was intended for flexible, if at times conflicting uses (Chandler 2006). This national priority of multi-use management mirrors international MPA trends. One study even suggests that 94% of MPAs allow fishing despite the overarching concerns about protection against overfishing in MPA creation (Costello and Ballantine 2015). While the concept of context dependent MPA development with a range of goals for protection is often acknowledged as a practical reality of conservation work, MPA literature makes a clear distinction between the perceived benefits of MPAs that allow for multiple uses as opposed to those which are partially or completely protected from extractive uses. All forms of MPAs are acknowledged as having some conservation potential, but no-take MPAs or MPAs that are strongly protected are held up as ideal forms of marine conservation with the greatest ecological benefits within some segments of the conservation community (Costello and Ballantine 2015, Jones 2014, Lubchenco and Grorud-Colvert 2015, NCEAS 2001, Sala and Giakoumi 2018.
Preference for no-take zones may be influenced by terrestrial conservation principles, but it is also supported by research indicating strong links between strict notake MPAs and increases in biodiversity, abundance, and ecosystem resilience (Lubchenco and Grorud-Colvert 2015). However, the perceived high conservation potential for strongly protected MPAs is marred by the simultaneous recognition that many of the world's MPAs are not achieving their conservation goals as a result of ineffective management and enforcement (Hargreaves-Allen et al. 2011, Jones 2014, Pomeroy et al. 2004. Additionally, many MPA sites have a strong focus on ecological research and monitoring, despite evidence that suggests addressing the social context of MPAs is central to their conservation effectiveness (Pomeroy et al. 2007, Wahle et al. 2003. Challenges in MPA management are not homogenous but themes of understaffing, underfunding, lack of high quality assessment, inability to address issues external to the MPA, and conflict with people who live, work, and play in the area of resource protection are common (Agardy et al. 2011, Gill et al. 2017, Hargreaves-Allen et al. 2011, Jones 2014, Lubchenco and Grorud-Colvert 2015. Beyond surface level management efforts to protect marine resources, MPAs are rooted in a particular set of beliefs that shape how we view threats to the ocean, as well as solutions. Some authors such as Bohnsack (2004) frame protection of ecosystems and human exclusion in some areas as a duty, implying that because we have the power to so dramatically alter the seascape, we must also take up the responsibility of protecting it.
Others such as Roberts (2012) and Costello and Ballantine (2015) highlight the rapid decline of many marine species and argue strongly for high levels of spatial protection as an immediate source of relief from concentrated human extraction.
While it is widely acknowledged that the world is undergoing an ecological transition and faces sharp declines in biodiversity, other authors such as Hillborn (2015) and Agardy et al. (2011) call into question the ability of MPAs to address central threats to the ocean such as climate change, ocean acidification, and pollution. In this context, much of the controversy over MPA development and perceived MPA failures is controversy over "protection" and non-biological factors that influence protection. For the purposes of this project, I will use the term "protection" to refer to the protection of both natural and cultural resources, unless otherwise specified.

Stellwagen Bank National Marine Sanctuary
The Since its designation in 1992, the Sanctuary has completed two management plans (1993,2010) and two sanctuary condition reports (2007,2020). The next management plan review process is scheduled to begin in spring of 2020. Additionally, the Sanctuary The rich concentration of marine organisms that result from the anomaly of the Bank's shallow depths have made this space a valuable source of sustenance for thousands of years (Terrell 1994). Archeological evidence suggests ancestors of people such as the Massachusett, Wampanoag, Nauset, Wabanaki, and Agawam, whose historical territories bordered the crescent of what is now known as Massachusetts Bay, made use of the plethora of wildlife supported by Stellwagen Bank and surrounding formations long before the arrival of white European settlers (Bernstein 2006, Terrell 1994 (Bernstein 2006, Mrozowski 1994, Terrell 1994).
In addition to biological features of Stellwagen Bank, the Sanctuary is also mandated by the NMSA and the National Historic Preservation Act to "locate, assess, protect, manage, and interpret" maritime heritage resources within its boundaries (GARFO 2018, pg. 2). So far research related to shipwrecks has been the primary focus of the Sanctuary's efforts to locate and document maritime heritage resources, although scholars such as Terrell (1994)

Research Justification and Methods:
Research to assess biological and socioeconomic dimensions of the sanctuary such fish stocks, cultural artifacts, and values associated with whale watch tourism is ongoing at SBNMS (ONMS, 2010(ONMS, , 2020. However, there has been little evaluation of the relationships between groups of people who use SBNMS and sanctuary managers and the impacts that these relationships may have on sanctuary management, a gap that parallels the direction of broader MPA research (Jones 2014, Morin 2001. Sanctuary management in this context refers to the broad range of education, outreach, and research and policy actions that comprise the Sanctuary's short-term and long-term direction. 2020 marks 28 years since SBNMS was designated, and while there have undoubtedly been many positive developments for the Sanctuary and the level of public awareness about the resources of Stellwagen Bank, the accomplishments of SBNMS are also viewed critically by those who feel the sanctuary has not adequately protected this area from pressures such as commercial fishing (Borrelli 2009, Owen 2002. Through understanding relationships among those who manage the sanctuary and those who use the sanctuary, this research project will add much needed social context to debates about the goals of the sanctuary. Inquiry into these topics is particularly relevant for SBNMS given the ongoing 2020 management plan review process. To date, there has been limited social science research on how the people and politics of SBNMS impact management processes and decisions at the site. This study centers on three major research questions: a) How have the roles and relationships among sanctuary managers and people who use resources in SBNMS evolved over time? b) How did/do these relationships influence sanctuary management? And c) How does social context shape what constitutes protection in an MPA? In this context, management refers primarily to the process and function of decision-making as opposed to management outcomes or formally written management objectives. These questions, along with related subquestions, will provide critical context for the sanctuary's current situation and will help managers, as well as people who use the sanctuary, understand the impacts of various groups on past and present policy. This research is important for understanding the immediate context of management decisions at the Sanctuary, but it also offers insights that may be helpful as the Sanctuary reevaluates its long-term vision for the future of people and organisms of Stellwagen Bank.
To begin to answer these questions, I used a suite of qualitative research methods to conduct an exploratory case study of the Sanctuary and its context. Case studies are valuable openings to examine complex phenomena related to a given place or topic. Indepth analysis of a site such as SBNMS enables novel information and connections that might be missed in research taking place on larger scales to be brought forward (Creswell et al. 2003). Some people had been to one or two SAC meetings whereas others are actively involved in creating and implementing Sanctuary policy. People I spoke with represented interests including commercial fishing, recreational fishing, conservation, and NOAA (including SBNMS staff). I used snowball sampling, also known as chain referral, to increase sample size and identify individuals whose role was referenced as important but not clearly defined by a SAC position or title (Bernard 2017).
Over the summer of 2019 I conducted 13 interviews, 12 in person and one over the phone. Interviews ranged in length from 45 minutes to 2.5 hours. Interviewees In addition, I attended SAC meetings, volunteered for ongoing research projects at the Sanctuary, and participated in Sanctuary events. These experiences were documented through field notes. Participant observation methodology allowed for in situ learning and the collection of data through personal interactions as well as non-verbal communication (Moore 2018). Researchers in other marine spatial management contexts have used similar participant observation methods to inform their work (Gray 2010, Wiener et al. 2009).

Document Analysis
Due to their respective roles as federal institutions, SBNMS and ONMS have left a thorough trail of public documentation. Texts such as management plan reviews, designation documents, public bulletins, and others provided an opportunity to compare and contrast perceived accounts of changes in management with documented accounts of changes in management. This portion of research was used to supplement interviews and participant observation and assess how people's perceptions related to official Sanctuary communications. This methodology is common to case study research and efforts to triangulate qualitative information for added clarity (Bowen 2009).

Methodological Reflection
The questions and methodologies I use in this project also mean that some notable elements of the Sanctuary's context are left out. Perhaps most importantly, my research was highly focused on understanding this particular site through the lens of existing management structures, and as a result, larger questions about the colonial nature of NOAA and scientific paradigms that inform management are not addressed (Smith 2013).
Additionally, by choosing to orient my work towards people who are already involved in Sanctuary management or who are known to Sanctuary managers, I wound up collecting data largely framed by existing hierarchies rather than data that lends itself to questioning the hierarchies of Sanctuary management. This thesis is thus a presentation of the beginnings of a more thorough and critical research project, rather than the final component of such a project.

Data Analysis and Presentation
Data collected through interviews, participant observation, and document analysis were organized and coded over the course of fall 2019 and winter 2020 (no software was used). Results were explored using practices from grounded theory to draw out recurring themes and to help make clear the mutually constructed perceptions of SBNMS that emerged from fieldwork (Charmaz and Belgrave 2012). This process means that not all information from notes or interviews was used. It allowed me to distinguish focal points of conversation, such as important events, people, and or beliefs, as well as subject areas that were rarely broached or missing from both my own questions and the responses of people involved in this project.
To begin to untangle the layers of people and politics that are tied to this physical space, Chapter 1 of this thesis focuses on what Stellwagen Bank and the Sanctuary have meant to people over time and what they mean to people now. This section provides the necessary context to understand why I asked the questions that led to evidence presented in the remaining sections. Chapter 2 demonstrates the ways in which a regional institution like the Sanctuary is enmeshed in a federal regulatory framework and how the weaknesses in this larger system of sanctuaries may impact SBNMS. This section provides the broader foundation from which the legacy of fishing in New England is explored in Chapter 3. Chapter 3 addresses the seemingly impervious legacy of fishing and raises important questions about how historical perspectives of resource use impact current management. Chapter 4 narrows the scope of analysis even further to institutional scale challenges in representation and explores how the Sanctuary's approaches to representation may impact its regional presence. Finally, Chapter 5 addresses how people view the Sanctuary's current direction as it relates to the concept of protection.
Collectively, the sections of this text are an initial attempt to contextualize and question the Sanctuary's current management decisions and directions. Through this project I hope to spark continued questioning and reflection about what the institution of SBNMS currently is and what it might become.

CHAPTER 1: Middle Bank and the Stealth Sanctuary
Stellwagen Bank has been recognized as a fertile fishing ground for thousands of years. Native peoples, such the Massachusett, Wampanoag, Nauset, Wabanaki, and Agawam inhabited, and continue to inhabit, what is now Massachusetts Bay (Native Land Digital 2018). These tribal nations likely had access to the area during the geological period when the bank was above sea level and supported terrestrial vegetation and coastal resources, around 12,000 -6,000 BP. Glacial melt and rising sea levels gradually reduced access to the area, and by the time white Europeans such as Captain John Smith arrived in the region in the early 1600s (ONMS 2020), Stellwagen Bank, then called Middle Bank or Middle Ground, was fully submerged (Terrell 1994). European scouts quickly recognized the abundance of fish and other marine organisms near Stellwagen Bank and used this wealth of resources to encourage colonial settlement (Borrelli 2009, Mather andJensen 2010). Fishing remains an important use of Stellwagen Bank to this day. Despite the diminished catch relative to historic quantities, combined fisheries resources extracted from the sanctuary between 2007-2016 were valued at over $194 million (ONMS 2020, Terrell 1994). This history of use and its position at the mouth of the Massachusetts Bay mean that Stellwagen Bank has been an important feature locally and within the larger Gulf of Maine system for thousands of years (Terrell 1994).
Stellwagen Bank's popularity as a fishing ground primarily relates to its natural geological features. The bank itself is an underwater plateau ranging from 65-120 ft. on the top to 300-600 ft. on the slopes and fissures that rim its edge. The benthic surface of the bank is a mix of boulders around the edges, gravel, sand, and mud bottom habitat.
The waters above Stellwagen Bank are full of life, as nutrient rich waters are pushed towards the surface by the rise of the bank and primary production flourishes. Although people often begin by describing the bank in terms of its depth and physical features, conversations soon drift to descriptions of the life these features support. One fisher described the area as a "garden" (Speaker 1), while another said, "it's almost like its own world out there" (Speaker 11).
Some fishers focused on the abundance of organisms such as whales, dolphins, fish, and seabirds, while others depict the area in more broad terms, saying, "the smell changes, the look of the water changes" (Speaker 2). A different person felt that although the resources are important, for them, Stellwagen Bank was and still is about the people.
Multiple fishers I spoke with had been active in what is now the Sanctuary well before its designation and before the establishment of many current fishing regulations. When thinking back to these early scenes on the water one fisher summarized the space as home to its own unique community, saying, "We never see these people except on Stellwagen Bank because that was kind of like the hub of a wheel… So that's what it means, mostly, to me, is a place where one guy yelling at us in Italian, another guy yelling at us in Portuguese and somebody else yelling in English" (Speaker 10).
Given these histories of use and the unique geological feature that lies at the center of SBNMS, this area has never been considered "empty" in the way that other spans of deeper ocean floor have been portrayed (Rock et al. 2019 wanted to allow sand and gravel mining on the bank or at least for this type of extractive activity to be assessed on a case by case basis rather than prohibited outright through a new Sanctuary (Dumanoski 1992, Sanctuaries andReserves Division 1993). Despite some internal federal resistance to designation, as proposals for mining and the construction of an artificial island and casino became public, support for the creation of the Sanctuary gained traction across political divides.
When asked to reflect on the designation process, one person described support for the Sanctuary as the result of an, "uneasy alliance of industry, conservationists, congressional delegates, and Massachusetts state delegates" (Speaker 6). While Stellwagen Bank's designation was directly related to the bottom habitat and rich resources that supported fishing and other commercial and recreational activities, there were no coordinated efforts to protect the area holistically prior to threat of development and mining. As one person summarized, "the Sanctuary was the means to the end" (Speaker 6). Commercial fishers were keen to protect vital bottom habitat from destructive uses, and many environmentalists, fueled by a growing body of research that supported the need for MPA development, were eager to enact long-term protections for a unique area under threat (Brody 1998, Speaker 6 (Telegram and Gazette 1993). Support like this from key politicians was essential in the Sanctuary's founding. In fact, given the success of the Sanctuary's approval, it was even rumored that then Vice President Al Gore would attend the event (although he did not) (Bigford 1993). However, the cheerful designation ceremony, marked by whale watch trips, exhibit fairs, and tours of the vessel Ferrel, and the broader alliance among politicians, fishers, and environmentalists, did not preclude ongoing and future debates about the purpose of the Sanctuary (Dedication Ceremony 1993).

Current Perceptions of the Sanctuary
Questions about the Sanctuary's purpose are reflected in early narratives of its designation. Despite the designation document which states that NOAA, "does not believe the imposition of Sanctuary fishing regulations would provide any constructive benefit to the issues currently addressed by other authorities" (Sanctuaries and Reserves Division 1993, pg. 125), the depletion of fisheries resources was, at times, referenced as the reason why the Sanctuary was created. Speaking at the designation ceremony, U.S.
Commerce Secretary Ron Brown said, "Three hundred years ago, fish were so plentiful that vast quantities could be harvested with nets placed in the harbors and rivers. But now, as with many of our national fishing grounds, Stellwagen Bank is in danger, with some species showing signs of actual stock depletion." (Telegram and Gazette 1993). A newspaper article described the Sanctuary as designed to "help protect the area from over-fishing and development" (Telegram and Gazette 1993). My own experiences on summer whale watch trips and in discussions with people who are not involved with fisheries management parallel these views about why the Sanctuary was created, as many people assume that resources within Sanctuary space are protected comprehensively including Sanctuary specific fisheries resources.
While the creation of the Sanctuary may have been peripherally related to efforts to stabilize groundfish stocks that had collapsed in the late 1980s, the Sanctuary's lack of direct authority in regulating fishing is at odds with public perceptions about the Sanctuary's work. One person summarized this by saying, "I think it may appear to some who just came into the sanctuary world recently like, okay, it's a sanctuary, but it doesn't really conserve enough" (Speaker 12). Some people attribute the historical and ongoing confusion about the Sanctuary's purpose to the term, "sanctuary" itself. As one person said, "You hear sanctuary, you just automatically think of protection, you know? But guys are still dragging, lobstering, scalloping on the Sanctuary…you know what I mean?
I mean I guess that's just the name of it, to me..." (Speaker 11). Perceptions of a sanctuary as off-limits, or a place of refuge were also common themes. One person even said, "you're operating from a disadvantage when the public thinks it's a sanctuary" due to the connotations of the word (Speaker 4), and another related the use of the term sanctuary to fears from commercial fishers that they will lose access to the space (Speaker 3). Even some people who are familiar with Sanctuary management at times expressed frustration about the term Sanctuary, highlighting the difficulty in completing work that feels at odds with the official label of the space.
In describing this tension between public perception and the actual work of the Sanctuary, one person referred to SBNMS as a "stealth sanctuary." Although they value the work of the Sanctuary because they are familiar with it, they felt that the Sanctuary is not using all available tools and that their work is often underappreciated by those outside of the management context (Speaker 6). Such disconnection from coastal communities surrounding Stellwagen Bank has been an ongoing challenge for SBNMS. Even in its early years, fresh off the success of designation, there are accounts of people wandering into the Sanctuary's newly established office in Plymouth, MA looking for an ATM because they saw the word "bank" on the sign outside (Speaker 2).
In addition, multiple people brought up the Sanctuary's location as a reason for its uphill battle for recognition. Unlike the Florida Keys National Marine Sanctuary, or others that are relatively close to shore, SBNMS is located twenty-five miles east of the Boston coast and three miles north of the tip of Cape Cod. As a result, access to the bank is restricted to those with the gear and knowledge to safely make the trip and to those who can afford tours or private charters. Although many coastal communities may be influenced by the resources of the bank, a relatively small proportion of people experience it firsthand. Thus, the challenge for SBNMS is to make many people care about a space that they often cannot see, may have never experienced, and that likely appears unrelated to their day to day lives (despite numerous social and ecological connections). To further complicate the situation, the Sanctuary, and more broadly the entire National Marine Sanctuary system, were often discussed as chronically the reasoning for the Sanctuary by saying, "It's good news for the whales, it's good news for the fish, and it's good news for the people who live here…" (Chaffee 1992). Yet, rather than try to classify the Sanctuary as either good or bad, it is important to iteratively ask who it serves now and how it could be improved to ensure that past notions of its purpose do not hold it back from its potential role in the long-term protection of Stellwagen Bank's cultural and natural resources. for'" (Speaker 4). Although it is not specifically referenced, this statement illustrates the underlying requirement to prove that an activity is harmful to restrict it rather to prove that an activity is safe in order to allow it. This default acceptance of the status quo is at the center of debates around how SBNMS should protect the Bank. As one person explained when discussing why the Sanctuary had not developed stronger on the water protections over time, it was "politically a little too difficult for the folks at NOAA to deal with" (Speaker 6).

CHAPTER 2: Legal and Institutional Framework
In addition to the influence of political support, criticisms of the NMSA largely center around the lack of clear authority or "teeth" (Speaker 6) in the law that prevents staff within the sanctuaries system from pursuing protection consistently. Unlike the Wilderness Act of 1964 which clearly lays out goals for management and preservation of wilderness, the NMSA has multiple objectives that are at times contradictory (Chandler and Gillelan 2007). For example, in Section 301(b)(3), the NMSA states one of its purposes as, "to maintain the natural biological communities in the national marine sanctuaries, and to protect, and, where appropriate, restore and enhance natural habitats, populations and ecological processes" (NMSA 2000). While most other sub-sections listed under this Purposes and Policies header relate to conservation or management in ways that align with this initial goal, Section 301(b) (6)  Gillelan (2007) illustrate, the multiple use clause in the NSMA can also be co-opted by industry interests and lobbyists to argue for no prohibitions on activities within sanctuaries or interpreted as a right to activity rather than context dependent privilege. As one person pointed out, managers are inclined to abide by the mandates of other federal legislation such as the Clean Water Act and the Magnuson-Stevens Act because, "That's what they get sued under" whereas the NMSA provides ample grey area that would make legal action more difficult (Speaker 6). Given this context, one person felt that even if the NMSA itself could not be substantially altered to clarify how sites should balance multiple uses, the ONMS giving guidance on decision making processes and saying, "we're going to help you figure out how to do that" would be "huge" (Speaker 4). While it is likely that guidance documents or recommendations about how to make decisions exist in some form across sites, consistency across the Sanctuary in terms of process, if not outcomes, was described as lacking by some interviewees (Speakers 2, 4). The grey area that constitutes compatible use varies from sanctuary to sanctuary, and it is typically shaped by regulations outlined in a site's designation document and/ or management plan (Farady 2006). Even though the Sanctuary published a hypothetical Sanctuary Compatibility Analysis Process (S-CAP) in 2010, it is unclear if and how this process has been applied ( Figure 4, ONMS 2010, pg. 217). Although this question was not asked directly, interviewees related to Sanctuary management through the SAC did not articulate detailed mechanisms through which decisions were discussed or made.
While it is possible that this project simply failed to capture details around decisionmaking processes, the lack of publicly available information about how specific issues have been deemed compatible or not is worthy of attention. Individual managers and Sanctuary staff were also discussed as an important influence on the level of communication about decisions and the overall direction of the Sanctuary.
Collectively, the lack of coherent federal vision for the sanctuary system and the frequent comparison among sanctuary sites may suggest that the National Marine Sanctuary Program is guided by precedent and individual sanctuary leadership rather than a broader consensus about basic sanctuary purposes and goals. In sanctuaries with strong community support or strong NGO support, this context dependent management style may be a benefit, as sites can tailor their management to local and regional needs and interests. However, for sanctuaries such as SBNMS, the absence of a robust structural framework for management may mean efforts to implement long-term protection are undermined by the flexibility of the NMSA and the strength of short-term local interests that favor extractive use.
While there is no universal solution for resolving the disconnection in federal and site-specific goals for resource protection, increased clarity in the NMSA with regards to the primary objectives for sanctuaries and system-wide protocols for decision-making would help establish a solid foundation from which to act. Multiple people I spoke with considered changes to the NMSA in the near future unlikely. SBNMS itself may have little power to impact system-wide structures for decision-making, and efforts to increase transparency and communication around important Sanctuary decisions will likely be constrained by staff time and funding. However, clarifying how criteria or workflows such as the S-CAP are actually applied to individual topics would be a useful first step in making Sanctuary decisions about compatibility visible to people beyond managers or the sanctuary advisory council (SAC). Additionally, presenting information about compatibility in a way that is accessible and easy to understand is necessary, as what information is available is primarily written for internal or scientific audiences (Dalton 2005). This regulatory context and the current weaknesses in the NMSA are particularly relevant when considering contentious issues in SBNMS such as fisheries management.

CHAPTER 3: Statues by the Sea and the Legacy of New England Fishing
The Sanctuary's ability to protect Stellwagen Bank is shaped by the federal structures that govern the broader national marine sanctuary system, but it is also strongly Confusion and debate about how the Sanctuary should operate in relation to other regional and federal authorities, combined with layers of regional history related to the Sanctuary's designation help complicate present understandings of fisheries management in Sanctuary space. Understanding how the Sanctuary has acted, and not acted, given this regional context will be useful as decision makers work to define Sanctuary goals for the coming years and the Sanctuary's role in managing the marine environment of Stellwagen Bank. Although evidence suggests the possibility of human cultural remains, one person said, "we haven't actually found that [evidence] or looked for it" (Speaker 7). But research and experiences beyond the Sanctuary's own work, such as fishers towing up mastodon skeletal remains on Stellwagen Bank (Terrell 1994) and research undertaken as part of the Rhode Island Ocean Special Area Management Plan that explores reconstructed paleo-landscapes (RI CRMC 2010, pgs. 61-63) and examples of other coastal archeological research in New England help demonstrate the possibility of human resources yet to be discovered (Bernstein 2006, Bolster 2006, Merwin et al. 2003, Waller 2000. Additionally, technological advances in maritime archeology may offer insights into the histories of Stellwagen Bank in ways that may not have seemed feasible at the outset of the Sanctuary's maritime heritage program (Bell 2009).
Exploration of the Sanctuary's past beyond shipwrecks and/or commercial activity is valuable in and of itself, but it is also an important step in helping correct erasure and histories of Massachusetts Bay that depict indigenous coastal peoples such as the Massachusett, Wampanoag, and other regional tribal nations as existing only in the past or that ignore their past and present existence entirely. This erasure has been linked in indigenous academic literature to, "a desire to remove indigenous peoples in order to access resources and land" (Hall 2008, Orr et al. 2019. Even when acknowledged, indigenous scholars such as Bruchac et al. (2016)  Further, because recognition, rights, and sovereignty for Native American peoples are closely tied to the historic record and continuity of occupation, how SBNMS portrays, or does not portray native peoples is significant to their ability to live, work, and play on their ancestral homelands (Bernstein 2006, Silliman 2009  Finally, through exploring the complexity of coastal and maritime lives in the past and present, the Sanctuary has an opportunity to reconnect broader constituencies with the coast by illuminating experiences of work and play beyond fishing. By disrupting a simplistic view of fishing in New England, the Sanctuary can begin to build support for stronger protection or protection that meets the needs of many different people and groups. As Bolster (2006, pg. 571) summarized, "The oceans' current crisis resulted from a century of vigorous fact-finding by scientists along with managers' reliance on numbers divorced from context, and politicians' satisfaction with exceedingly short-term solutions. If there was ever a dilemma crying out for historians' sensibilities, this is it." Although lack of funding is a pervasive concern when it comes to supporting and managing the Sanctuary's projects, perpetuating the erasure of indigenous peoples through inaction and inadequate historical context of the diversity of past and present day resource users is also costly in terms of how the dominance of a particular view of New England fishing impacts support from the public and the fishing industry. While fishing activities may be a fruitful starting point for this research, native peoples and others who live along the coast that borders Stellwagen Bank undoubtedly use Sanctuary resources in a variety of ways, and the prominence of fishing in conversations of resource use should not negate exploration of other connections to this space.

The Promise
In conjunction with the broader, regional dynamics of the Sanctuary's history, the more immediate story of the Sanctuary's designation is an important, and evolving, influence on its current distance from fisheries management practices. In discussions about the Sanctuary's role in fisheries management, one story was brought up more than any other: the Promise. The story of the Promise involves a range of actors, including New England congressional delegates, Sanctuary advocates, NGOs, and prominent fishing industry representatives. It represents different things to different people and was used to explain why the Sanctuary should or should not be involved in fisheries management as well as to argue for increased Sanctuary outreach. Perhaps most importantly, the meaning of the Promise was described by multiple people as in flux. I found that the context of changing environmental conditions as well as the presence or absence of certain? people altered how the impacts of the Promise were viewed.
In the late 1980s and early 1990s, the fishing industry expressed strong opposition to the Sanctuary's designation. Given the power of the fishing lobby at that time, the congressional champions of the Sanctuary, Congressman Gerry Studds and Senator John Kerry, among others, felt that the Sanctuary's designation would not be politically feasible without the industry's support. One person described attitudes at that time as, "you have to give up something to save something" (Speaker 5). In order to move the designation forward, fishery representatives and Sanctuary advocates brokered a deal. As Resource Management] does not believe the imposition of Sanctuary fishing regulations would provide any constructive benefit to the issues currently being addressed by other authorities" (Sanctuaries and Reserves Division 1993, pg. 125). As the primary fear of many fishers was, and continues to be, loss of fishing access, this meeting was pivotal in uniting fishers with conservationists against the common threat of gravel mining and nonfishery-based commercial development.
Despite this promise, tensions remained high, and in that same year, a fisher who claimed, "special knowledge of the designation process" made calls to other fishers urging them to not put their trust in "NOAA folks" (Bigford 1991). Overarching distrust of NOAA was central to fishers' concerns throughout the designation process, but multiple people also stated that individual Sanctuary staff members were an important factor in early relationships with the fishing industry and fisheries managers. Although advocates for the Sanctuary had promised only a few years prior that the Sanctuary's creation would not impact the fishing regulations already in place through the regional council, questions of who had made that promise and the scope of the promise are contested. While some interpreted the Promise as the Sanctuary's indefinite abdication of authority related to fisheries management, others took it to mean that the Sanctuary as negative initial interactions between the Sanctuary and other regional authorities such as the NEFMC. However, one person related to NOAA also described an underlying reluctance to make space for the new institution saying that upon entering a meeting they were told by a fellow NOAA representative, "If you want something said, you say it to me and then I will say it if I think that it's worth saying" (Speaker 2).
Although current relationships between Sanctuary staff and other regional authorities are described in a significantly more positive light, the underlying discord related to the Sanctuary's involvement in fisheries management has not evaporated.  a necessary safeguard against overexploitation, one fisher said, "we really need to take care of the whole ocean, not just 600 and odd square miles of it" (Speaker 10). This same person followed up by stating, "it's really ironic that I literally have more history there than a lot of people and they're saying no, you're a human, you don't belong in that ecosystem; I was there for 50 years. That doesn't count. I wasn't dealing with mastodons who were walking around when it was dry land" (Speaker 10). Another person stated that they did not support Sanctuary involvement in fisheries management because other bodies such as the NEFMC have, "a public participation process that we're comfortable with" (Speaker 13). Concern about representation was often tied to stories of past issues with specific staff members and while one person in the Sanctuary office acknowledged the importance of the Promise, they said that they, "haven't heard anyone invoke the Promise for a long time." However, it is unclear whether the extent to which invocations of the Promise decreased because of changing attitudes about the Sanctuary's role in fisheries management or as a result of changing Sanctuary goals related to fisheries management. Additionally, conversations with fishers about the Promise frequently turned into discussions of the hope sparked by the Sanctuary's efforts to rebuild relationships with the commercial and recreational fishing communities through outreach and the appointment of the new superintendent, Peter DeCola.
Given this context, opposition to the Sanctuary's involvement in fisheries management may be more strongly related to contested views on the overarching role of the Sanctuary in fisheries management and the perceived fairness of input rather than specific objections to a particular management action. Ongoing and future research to map changes in the biological resources of Stellwagen Bank is essential to support the Sanctuary's mission. However, renegotiating the place of SBNMS within the context of New England fishing and rebuilding/building strong relationships with fishers of all types is the necessary foundation that will allow Sanctuary research to be applied.
People discussed the Sanctuary as already in the process of rebuilding relationships with fishing communities. However, lingering misconceptions about the Sanctuary's current role in fisheries management may serve to keep fears that fishers would lose access to Stellwagen Bank fishing ground alive. Clear concise, messaging in the form of flow charts, graphs, or other imagery to demonstrate the relationship among various branches of NOAA agencies and the Sanctuary could be a useful tool in working to combat these misunderstandings. Additionally, efforts to help illuminate the historical and ongoing fishing by indigenous peoples, as well as the diversity of non-indigenous contemporary fishers could be an critical first step in understanding resource use as an ever-evolving relationship with the marine environment rather than a static way of life.
While Sanctuary funds for supporting social science and historical research internally are limited, it has had past success with community and academic partners that may provide footing for new projects. At the very least, expansion of maritime heritage work beyond shipwrecks could be identified in the upcoming management plan draft as a long-term goal to signal to other institutions and potential partners intentions to broaden the Sanctuary's scope of research.

CHAPTER 4: In Search of Representation
In addition to the impacts of federal and regional social contexts on SBNMS management, individuals and relationships at the institutional level were also discussed as key factors that swayed the direction of management. In particular, relationships among Sanctuary Advisory Council (SAC) members and between SAC members and Sanctuary staff were viewed through the lens of past discord but also as an opportunity for growth.
Additionally, some related the structure and processes of the SAC to current management Efforts to increase public participation in MPA management are not new and have increased steadily in recent decades (Brody 1998, Dalton 2005, Kaza 1988, Reed 2008, Voyer et al. 2013. Within debates about how to best integrate the values of a wide range of people with vested interests in a space, questions related to the extent to which agreement is beneficial are common (Peterson et al. 2005). Although the SAC at SBNMS makes most decisions based on a majority vote as opposed to consensus (some working groups may seek consensus), some people were still concerned with the illusion of consensus that can result from voting outcomes. Because the distribution of seats is relatively unchanging (although not permanent), one fisher felt that because there were more seats allotted to people who are likely conservation oriented, the presence of fishing seats was largely symbolic rather than meaningful (Speaker 13). In contrast, another SAC member expressed frustration with what they perceived as regulatory capture, or the dominance of fishing industry representatives in the management of marine resources overall. They felt that to truly achieve more balanced representation, more seats on the SAC should be given to those representing the natural resources of the sanctuary, including right whales, herring, cod, and haddock" (Speaker 4). In addition, multiple Other interviewees who did not focus on a need for information articulated that frustrations with the SAC processes related to communication before, during, and after SAC meetings. One SAC member expressed a desire for better distribution of topics and information prior to the meetings themselves, saying that it was difficult to have productive conversations when the SAC is "blindsided" by a question (Speaker 8). While some agenda information is provided prior to SAC meetings, this person felt that more specific information about the types of decisions that would need to be made for any given issue could help prime people for better dialogue (Speaker 8).
To further improve meeting discussions, others felt that greater connection among SAC members would improve their ability to have open discussions and come to decisions. One person mentioned that it would be helpful to know people beyond their position and their official capacity. For example, in the midst of one SAC retreat, some SAC members watched a world series baseball game together after hours. Although the impacts of that single event are hard to assess, this person felt it was a moment that likely had a positive influence on the ability of the group to work together the following day.
Finally, multiple people expressed a desire for better follow-up about decisions and discussions after a SAC meeting takes place. Some interest in this post-meeting follow-up related to past events in which reports and draft documents that were, in part, the result of SAC efforts then disappeared into a "Sanctuary black hole" (Speaker 6).
Beyond any specific event, one person felt that some form of simple summary or notice from the Sanctuary about actual outcomes and decisions from SAC discussion (if not finalized during the meeting), as opposed to just meeting notes, would help them better prepare for next steps and feel as though their voices were valued.
Additionally, the role of individual people in the successes and shortcomings of the SAC was discussed as a cross-cutting issue. Sanctuary superintendents were described as each setting a different tone during their tenure for the role of the SAC. One person described past superintendents as taking actions that were, "independent of what we [the SAC] said or recommended" (Speaker 13). Although the role of the council as advisory was clearly acknowledged, people articulated that the dismissive nature of past relationships impacted the ability of the SAC to function to its highest potential and the willingness of SAC members to dedicate their time and energy to the process. While not all feedback on past superintendents was negative, multiple people perceived the new superintendent, Pete DeCola, and his actions thus far as a positive change. One person stated, "I think it's refreshing we have Pete who will listen, and we think he will be fair.
Because that wasn't the case with the previous superintendent" (Speaker 13).
In addition to those who are directly involved with SAC leadership, some people brought up individual SAC members and expectations for members as having an important influence on the outcomes of SAC meetings. Even preliminary aspects of SAC involvement such as how members are selected to be on the SAC were discussed with one person saying, "we should be prioritizing the community representation that's directly tied to a constituency that's affected over someone who maybe has either more of a pedigree or more to offer the sanctuary, but isn't necessarily tied to the community as closely" (Speaker 8). Concern over the influence of individual actors also carried over to meeting participation. When asked if they thought the SAC functions as it was intended to, one person described some SAC members as focused on their own interests saying, "I don't think most members of the SAC are helping the Sanctuary do their job" (Speaker 4). In this case, the job of a SAC member was viewed as offering expertise and input to further the Sanctuary's mission, as opposed to occupying a seat to protect the interests of a particular sector.
Reinforcing this, someone else said, "Are they there to serve the Sanctuary or are they there to serve their community, or both?" (Speaker 8). This quote was emblematic of the lack of clarity around the extent to which current members are required to communicate with the groups that they theoretically represent. Although SAC members are required to list ways they will communicate with the groups they represent on their application, one person said, "We really don't supervise or oversee SAC performance...that's why I say so much of the success of the SAC comes down to who's on it" (Speaker 8). While some SAC members did discuss actively sharing information with the groups they represent, communication was limited to immediate co-workers and largely issue-based, meaning fishers may only share fishery related news.
Aside from the details of SAC duties, for those who have been involved with the SAC for many years, attending meetings and enduring the often prolonged decision- The most recent Sanctuary Condition Report, released in the spring of 2020, provides some insight into future management priorities through discussion and representation of topics (ONMS 2020). Issues such as climate change, pollution, fishing impacts, and demand for recreation in the Sanctuary, all of which were brought up in interviews along with education and outreach, are prominently addressed. The report also highlights institutional strengths in research stating that the Sanctuary is at the, "forefront of anthropogenic noise and humpback and fin whale research" (ONMS 2020, pg. 16).
Qualitative feedback from interviews corroborates this view of the Sanctuary as a leader in expanding knowledge about the resources of Stellwagen Bank.
The Condition Report also acknowledges scarcity of socioeconomic information for many topics such as commercial and recreational fishing, maritime heritage, nonconsumptive recreation, and sense of place, among others. Although education in the Sanctuary is rated as "good" with a trend of "improving," the absence of robust social data across activities and groups of people who use Stellwagen Bank may undermine the Sanctuary's education and outreach programming given that understanding target audiences is key to both enterprises (Jacobson et al. 2015, Mahoney and Tang 2016, Mealor and Frost 2012. While MPA management and research has long been driven by a natural science focus (De Santo 2013, Wahle et al. 2003), the lack of social science data is particularly important for sites such as SBNMS that face unique challenges in site access and complicated regional histories that may act as a barrier to support for Sanctuary work.
In contrast with the Condition Report's statement that frames education as a service that, "does not substantially affect the state of natural and cultural resources," (ONMS 2020, pg. 166) many people I spoke with did not distinguish education from other efforts to protect Stellwagen's resources such as potential on the water regulations.
When asked about what issues should be a priority for the Sanctuary in the coming years, education and outreach were mentioned by a majority of those interviewed. One person said that education and outreach represent, "the main ability that the sanctuary has to foster conservation" (Speaker 3). This view was paralleled by others who viewed education and outreach as realistic opportunities through which to build support for the Sanctuary's work within groups such as fishers who may be wary of NOAA oversight outside of a more formal participation process (Speaker 5).This suggests that they view education and outreach as central to goals for the Sanctuary's work to protect resources, rather than as peripheral or of lesser importance to protection.
The work of the current Education Coordinator and the Volunteer Program and SAC Coordinator was generally characterized as successful, and many felt that the Sanctuary's public presence had expanded in recent years. One person said, "the Sanctuary is increasingly successful at getting itself known in the community" (Speaker 4), while another said, "I think it's embracing its role as being very important in communication, two-way communication with all the resource users, and education and outreach" (Speaker 3). However, despite positive reflections on current work, multiple people felt that the Sanctuary should be doing more to develop its regional presence and connect people with the Sanctuary in their backyard.
Funding limitations were acknowledged as an important reality of the Sanctuary's work, and multiple people expressed doubt about the ability of the Sanctuary to expand its staff or programming in the current context (Reeves 2000). However, beyond the simple quantity of outreach programs and efforts, one person questioned the overall direction of outreach at the Sanctuary saying, it's never felt like there's a very coordinated outreach strategy" (Speaker 6). In this context, the Speaker was, in part, questioning what key groups the Sanctuary is attempting to reach. In another casual conversation someone else mentioned that, likely due to funding, the Sanctuary seems opportunistic in its approach with regards to who it targets and how it targets them. Both critiques were a reflection of overarching Sanctuary priorities rather than any individual person or position. In the context of SBNMS, while the value and importance of natural and cultural resources on Stellwagen Bank is widely acknowledged, how to protect these resources is contested. For some, strong protection and conservation of resources requires on the water protection to restrict activities such as fishing. MPA literature places a heavy emphasis on direct restriction of human activity in marine environments. These methods of protection offer many immediate benefits and should by no means be discounted (Costello and Ballantine 2015, Jones 2014, Lubchenco and Grorud-Colvert 2015.
However, MPAs may be incapable of enacting strict on the water protections for a number of reasons such as community resistance or lack of funding. In these instances, labeling MPAs as failures due to lack of on the water regulations ignores the potential for these institutions to work towards long-term protection and shifts in social norms through other means such as education and outreach.
Additionally, evidence from this exploratory research suggests that the importance of education to interviewees may mean that education could be an alternative embodiment of protection as a result of its potential indirect impacts on the environment.
While education and outreach programming may be valuable to the Sanctuary for many reasons, the long-term influence of this work in building relationships between the Sanctuary institution and coastal communities and between coastal communities and ocean resources may factor into the ability of the Sanctuary to enact more stringent protections in the future. Experience on the water and knowledge about Stellwagen Bank were discussed on whale watch tours and in and around the Sanctuary office as key factors in making the Sanctuary important to people whose livelihoods are not directly tied to its resources. As one naturalist on a whale watch tour said, "Once they see a whale, they're hooked. They remember it way after they get off the boat." Articulating education as one form, or alternate embodiment, of long-term protection as opposed to an activity that is beneficial but unrelated to "the state of natural and cultural resources" (ONMS 2020, pg. 166) could be useful in clarifying the ways in which SBNMS does actively protect natural and cultural resources despite few on the water regulations. While the Sanctuary may be limited by federal frameworks and language with regards to how it labels and addresses education and outreach in formal documents such as management plans, this does not preclude efforts to alter any barriers to reframing education and outreach or small local shifts in how these programs are approached. Increased prioritization of education and outreach programming through funding and staff time is one critical, yet unlikely based on interviewee feedback, path to building community presence and relationships. Based on what a few people related to Sanctuary management said, staff simply cannot reach all of the communities they would like to and cannot complete all of the projects they would like to given the current situation (this could be said of any of the Sanctuary's programs, but was described in particular reference to education).
Aside from changes to money and time, the Sanctuary could examine low-cost alternatives such as continued expansion of its social media presence and the cultivation of strategic partnerships with universities and NGOs to help increase its presence in the region. Ultimately, renegotiating the role of education and outreach in protection may help challenge conventional understandings of what constitutes a successful MPA and expand what solutions are viewed as possible to environmental degradation. While some people I spoke with expressed dismay and even anger at the expansion and "co-optation" of the term MPA to include spaces that do not have strong on the water protections, reflection on forms of protection that are more attuned to values and beliefs associated with ocean activity may be one, out of many tools, to prevent destruction of marine spaces and build relationships from shore to sea and back again.

Conclusions
Stellwagen Bank, both the feature and the forms of life it supports, are shaped by a confluence of federal, regional, and local elements. While the general form of the plateau may remain fairly constant, its surface is regularly swept by dredges and storms, and the waters above it are churned by myriad human and non-human marine life.
Despite its distance from the buzz of activity on New England's shore and the seemingly placid jostle of the waves on a smooth, calm day, as one person said, Stellwagen Bank and the Sanctuary that now encompasses it, "is not a mythical place where nothing changes" (Speaker 10). In fact, movement and change have been Stellwagen's defining features for thousands of years as it transitioned from a site of dry land that likely supported early coastal peoples to a watery platform that now serves as a focal point for travel, commerce, fishing, tourism, marine life and as a rich cultural landscape.
Management of this ever-changing space is inherently tied to the foundational Once these elements have been decided, there is an underlying assumption both within conversations about SBNMS and the broader MPA literature that those protections will be applied through regulations that govern on the water activity. While direct action on the water is a logical final step of protection, conceptualizing protection as something that only occurs on the water obscures very real influences of cultural values and coastal politics on marine space.
Evidence from interviews and conversations with people who are involved or interested in the management of Stellwagen Bank suggests that the Sanctuary's education and outreach programming is central to how people perceive its purpose. As the Sanctuary continues to examine and reevaluate its direction through the 2020 management plan review process, making the ways in which protection takes place on sea and on shore explicit may be a useful foothold in solidifying and articulating its purpose to people who are critical of its limited on the water regulations.
Increasing the number of interviews I conducted and the amount of time I spent on and around Stellwagen Bank may have added greater nuance to perceptions of the Sanctuary's evolution over time. Although the deeper historical context of Stellwagen and the portrayal of fishing history primarily through the lens of white settlers became an important finding, I did not specifically contact or speak with anyone who identified as indigenous to explore ongoing challenges in access and representation in management of marine spaces.
Additionally, my strong focus on meeting with people who have been, or are currently, involved in management as opposed to prioritizing speaking with people who are diverse in terms of race, gender, ability, occupation, culture, and other elements of social identity resulted in a collection of interviews with people who are white and primarily men. This means that my data may not be fully representative of the Sanctuary's social context over time and that my methods, and data are missing key aspects of social identity that may also influence management decisions. My research methodologies and analysis additionally did not extend to the broader systems of management, as I did not include targeted analysis of NOAA as an institution or the scientific frameworks that support its work. Ultimately, this project was limited by funding and time.
In terms of future research, expanding insights from people who beyond this narrow subset of people in terms of identity and relation to the Sanctuary would be a useful next step in gauging perceptions of the Sanctuary's goals and actions.
Additionally, given the range of purposes and management actions across national marine 11. How would describe the direction of management at the sanctuary now?
12. What do you think should be a priority in the upcoming sanctuary management plan review process?