On November 4, 2013, the Center for Regulatory Effectiveness filed comments on the U. S. National Marine Fisheries Service’s proposed extension of its Information Collection Request covering oil and gas seismic and some other “Takes” of marine mammals under the U.S. Marine Mammal Protection Act. Under the U.S. Paperwork Reduction Act, the Office of Management and Budget has to review and approve this ICR before NMFS can collect the information it covers.
CRE’s comments made the following and other points.
The proposed extension ICR contains burden estimates that are inconsistent with the burden estimates in the current ICR.
Neither the current ICR nor the proposed extension ICR could possibly cover MMPA Take rules for oil and gas seismic in the Gulf of Mexico because there are no such rules yet. NMFS will need to allow additional public comment on a new ICR for any such rules.
Neither the current ICR nor the proposed extension ICR could possibly cover new MMPA acoustic criteria for oil and gas seismic because there are no such new criteria yet. NMFS will need to allow additional public comment on a new ICR for any new criteria.
NMFS will have to demonstrate that ICRs for GOM Take Rules and for new acoustic criteria comply with Information Quality Act (“IQA”) Guidelines.
NMFS should take the actions set forth below in section VI of these comments.
Click here to read CRE’s comments.
