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Soundings Archive

CRE Comments on Draft SARS Guidelines
On March 23, 2012, CRE filed comments on the National Marine Fisheries Service's draft guidelines for assessing marine mammal stocks ("Guidelines") and on NMFS' Report of the GAMMS III Workshop, NOAA-NMFS-2012-0007 ("GAMMS Report"), 77 FR 3450 (Jan. 24, 2012). CRE's comments made the following points.

NMFS should revise the Guidelines and GAMMS Report to discuss and comply with Information Quality Act ("IQA") requirements. For example:

  • There should be a record showing that the Guidelines and GAMMS Report comply with the IQA Pre-dissemination review requirements;

  • All models that the Guidelines or GAMMS Report use or rely on should be peer reviewed in order to determine their compliance with Council for Regulatory Environmental Modeling ("CREM") Guidance;

  • The method used by the Guidelines and GAMMS Report to estimate population uncertainty violates the IQA accuracy and reliability requirement; and, as a final example,

  • The Guidelines and GAMMS Report violate the IQA accuracy and reliability requirements by telling staff to make up abundance data and PBR when measured data don't exist.
CRE also commented that NMFS should revise the Guidelines and GAMMS Report to delete any suggestion that marine mammal Stock Assessment Reports should discuss oil and gas seismic effects. Any such suggestion is inappropriate because:
  • Oil and gas seismic operations do not cause mortality or serious injury to marine mammals; and

  • Oil and gas seismic operations do not cause a decline or impede recovery of any strategic stock.
CRE also commented that the Guidelines and GAMMS Report should be revised to delete any suggestion that a mere "disturbance" or "non-serious injury" is sufficient to be included in marine mammal SARs. SARs should only include events--in particular commercial fishing events--which cause mortality or serious injury, or which can be shown to cause the decline or impede the recovery of a strategic stock. This has been NMFS' position in the past, it is correct, and it should not be changed.
  • Click here to read CRE's comments
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