The U.S. National Marine Fisheries Service has issued an incidental harassment authorization (IHA) under the Marine Mammal Protection Act to Lamont-Doherty Earth Observatory to incidentally harass, by Level A and Level B harassment, marine mammals during seismic activities associated with a marine geophysical survey in the Northeast Pacific Ocean. This Authorization is effective from July 10, 2019 through July 9, 2020.
The Marine Mammal Commission filed comment on the proposed IHA that criticized the take models used in L-DEO’s IHA application. NMFS reject MMC’s criticisms for the following and other reasons:
“The use of models for calculating Level A and Level B harassment zones and for developing take estimates is not a requirement of the MMPA incidental take authorization process. Further, NMFS does not prescribe specific model parameters nor a specific model for applicants as part of the MMPA incidental take authorization process at this time, although we do review methods to ensure they adequately predict take. There is a level of variability not only with parameters in the models, but also the uncertainty associated with data used in models, and therefore, the quality of the model results submitted by applicants. NMFS considers this variability when evaluating applications and the take estimates and mitigation measures that the model informs. NMFS takes into consideration the model used, and its results, in determining the potential impacts to marine mammals; however, it is just one component of the analysis during the MMPA authorization process as NMFS also takes into consideration other factors associated with the activity (e.g., geographic location, duration of activities, context, sound source intensity, etc.).”
“Use of the L-DEO model is further supported by ten years of successful operations with no observed harm to marine life.”
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