CRE Files Comments on BOEMRE's Revised Take Application for Gulf of Mexico Seismic
On July 13, 2011, CRE filed comments on BOEMRE's revised application to NMFS for rules under the Marine Mammal Protection Act authorizing Takes of marine mammals from oil and gas seismic operations in the Gulf of Mexico. BOEMRE's 2011 application revises BOEMRE's (then MMS) earlier 2004 application, which NMFS has not yet acted on.
CRE's comments included the following points.
NMFS should issue GoM Take regulations based on BOEMRE's (then MMS) earlier 2004 Take Application to NMFS ("2004 Application"), except that the Southall Criteria should be used for Level A Takes because these criteria are more accurate.
The 2004 Application is available online at available online at http://www.nmfs.noaa.gov/pr/pdfs/permits/mms_gom_seismic_application2004.pdf
CRE requests that NMFS and/or BOEMRE conduct external peer review of the Acoustic Integration Model. This Peer Review should address, among other issues, whether the behavioral effects data input into the AIM model are adequate for the model to be used to estimate Takes of marine mammals in the GoM
This peer review should comply with OMB's Final Information Quality Bulletin for Peer Review, which is available online at http://www.whitehouse.gov/sites/default/files/omb/memoranda/fy2005/m05-03.pdf .
The peer reviewers should be advised of the Information Quality Act Guidelines applicable to BOEMRE and NMFS. They should also be advised of EPA's CREM Guidance for models.
The BOEMRE IQA guidelines are available online at http://www.boemre.gov/qualityinfo .
The NOAA/NMFS IQA Guidelines are available online at http://www.nmfs.noaa.gov/quality.htm .
EPA's CREM Guidance is available online at http://www.epa.gov/crem/cremlib.html.
CRE's full comments are attached herewith . We encourage the public to participate in this regulatory action by submitting their comments in the space below.
Copyright © 2005 The Center for Regulatory
All rights reserved.