The Center for Regulatory Effectiveness has filed comments on the U.N.’s Convention for the Conservation of Migratory Species of Wild Animals document “Addressing the adverse impact of underwater noise on migratory species.” CRE’s comments made the following points, among others.
The technical guidance documents for this UN Voluntary Commitment use and rely on a recent U.S. National Oceanic and Atmospheric Administration Document that CMS refers to as “(NOAA, 2016).” This NOAA document is often referred to as NOAA’s Acoustic Guidance.
The Center for Regulatory Effectiveness recommends that CMS not use or rely on (NOAA, 2016) at this time for several reasons, including the following.
First, NOAA is in the process of determining whether to rescind or revise (NOAA, 2016).
Second, (NOAA, 2016) does not comply with the U.S. Information Quality Act and Guidelines; consequently, U.S. Government Agencies cannot use or rely on (NOAA, 2016).
