CRE Comments on Atlantic IHAs

On July 5, 2017, the Center for Regulatory Effectiveness researched and drafted comments to the U.S. National Marine Fisheries Service on Taking Marine Mammals Incidental to Geophysical Surveys in the Atlantic Ocean, 82 FR 26244 (June 6, 2017).

CRE’s draft comments agree with NMFS proposed use of a 500 meter exclusion zone as a mitigation measure.

CRE also agrees with NMFS’ proposed compliance with the MMPA’s “small numbers” requirement “through comparison of the estimated number of individuals expected to be taken to an estimation of the relevant species or stock size.”

CRE also agrees with NMFS that determination of “small numbers” should always take “into consideration the implementation of the proposed monitoring and mitigation measures.”

CRE also agrees with NMFS that Passive Acoustic Monitoring should be

CRE does not agree with NMFS’ proposed use of its new Acoustic Guidance. CRE will address the Acoustic Guidance issue in CRE’s comments to be filed on or before July 17, 2017, on the Acoustic Guidance’s compliance with Executive Order 13795.

Click here to read CRE’s filed comments.

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