On July 1, 2016, the Center for Regulatory Effectiveness submitted comments on NOAA’s draft Ocean Noise Strategy Roadmap. CRE’s comments included the following points:
– Information Quality Act (“IQA”) compliance is required for all NOAA-disseminated information;
– All models used by NOAA must be properly validated, which includes verification through comparison with empirical data; and
– The draft Roadmap should be corrected and revised to explain that NOAA’s new acoustic threshold guidance was developed in violation of OMB’s Peer Review Bulletin requirements, and in violation of NOAA’s IQA Guideline, and should not be used in its current state.
