NOAA is proposing a regulation dealing with takes in the Gulf of Mexico. The regulation is based on the output of models which have not been calibrated and do not produce reproducible results.
The use of such models is illegal under the Data Quality Act.
The Library contains:
Demonstrates that that NOAA Acoustic Guidance only addresses 25% of the datasets inherent in the regulation of seismic operations and at that, the least consequential of the said datasets.
(2) Models CREM 1
In January 2013 CRE presented to NOAA a report which concluded that:
The use of computer models like AIM to estimate Takes unreasonably increases the number of Takes over those estimated by line transect. Use of line transect to estimate Takes is consistent with NMFS’ use of line transect, and not AIM, to estimate Takes under the MMPA.
