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


The thrust of the comments is that marine mammals are being protected by the existing regulatory regimen and there is no need to reinvent the wheel.

 See the attachments  below for the details behind this conclusion.


The proposal flags a new direction in seismic regulation

 (1)   The authorization of a fixed number of takes, a “takes” budget

(2)   The use of a new mathematical model to replace AIM


A significant number of environmental groups have latched on to the large number of takes identified by the Navy and made such a finding central to their opposition in a related proceeding.


Also see this post on the statements of influential organizations on marine sound

The aforementioned documents are:



Enviro Comments Navy Take


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