CRE’s September 27, 2017 comments to NMFS criticized NMFS’ intended use of its Acoustic Guidance for the following and other reasons.
First, the Acoustic Guidance may not exist much longer. The Department of Commerce and NOAA are in the middle of a process to determine whether to rescind or revise the Guidance.
Second, OMB has not authorized an Information Collection Request (“ICR”) for the Acoustic Guidance. NMFS cannot force anyone to use the Acoustic Guidance, or penalize anyone for not using the Acoustic Guidance, without an OMB-approved ICR for it.