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SCB Marine & North America sections comment on proposed NOAA guidelines for assessing noise effects on marine mammals

On 13th March, 2014, the Marine and North American Sections of the Society for Conservation Biology submitted comments to the National Oceanic and Atmospheric Administration (NOAA) regarding their proposed Draft Guidance for Assessing the Effects of Anthropogenic Sound on Marine Mammals Acoustic Threshold Levels for Onset of Permanent and Temporary Threshold Shifts. A number of concerns were expressed. Most fundamentally, SCB criticised the procedures used to establish the criteria values, which were underestimating the total take as they were based on means and median values, rather than considering population distributions. Other comments addressed the coverage of the hearing weighting functions; the inconsistent treatment of data; and the criteria values themselves. The comments also recommended that NOAA drop their chosen criteria format in favour of the more conservative and also much simpler alternative criteria also presented in the Draft Criteria for use by those with less acoustic expertise. Such a change would simplify implementation for all authorization applicants, as well as those processing and reviewing the applications, including the associated public comments. This would increase process transparency and reduce application handling times.

The full comment letter can be accessed here.