CRE Comments on NMFS Proposed Rule:Takes of Marine Mammals Incidental to Specified Activities


NMFS officials have been quoted as saying that the regulatory regime embodied in the aforementioned proposal could be representative of the paradigm which could emerge as a result of analyses being performed in response  to  the BOEM petition on takes.


in response to the possibility that the resultant proceeding could be precedent setting, CRE filed two comments:

 1)   The State of Seismic Regulation in the Gulf of Mexico

 2)  Navy’s Modeled Marine Mammal Take Estimates Conflict with Real World Observations


CRE Comments on the Atlantic Take Rules

 Numerous individual citizens have already filed comments on these proposed rules. Most of these comments criticize and oppose these proposed rules, in large part because they authorize a number of marine mammal takes that the commenters believe to be excessive.

 CRE respects these individuals’ right to comment, and we commend them for exercising that right. However, they may be misguided.

 The estimated takes in the proposed rules are based on Navy computer modeling that is inconsistent with real world observations.

 See complete submission below.