Advocacy Submits Comment to NMFS on Amendments to the North Atlantic Right Whale Vessel Strike Reduction Rule
On August 1, 2022, the U.S. Department of Commerce’s National Marine Fisheries Service (NMFS) published a proposed rule titled, “Amendments to the North Atlantic Right Whale Vessel Strike Reduction Rule.” The Office of Advocacy of the U.S. Small Business Administration (Advocacy) respectfully submits the following comments on the proposed rule. Both Advocacy and the small entities that consulted with Advocacy strongly agree that protection of right whales must remain a priority for all who engage in maritime activities. While these small entities are committed to finding ways to ensure that vessel strikes are minimized, this proposed rule would further restrict an already heavily regulated and compliant maritime industry. Advocacy therefore encourages NMFS to consider alternatives to the proposed rule that would meet the stated objectives of conserving right whales while minimizing the burden to affected small businesses.