The Center for Sportfishing Policy (CSP) formally commented in response to the National Marine Fisheries Service's (NMFS) Advance Notice of Proposed Rulemaking (ANPRM) regarding the 2008 North Atlantic Right Whale Vessel Strike Reduction Rule, urging NOAA to embrace a modern, technology-driven, non-regulatory approach to whale conservation. The public comment period on the ANPRM closed June 2.
In its formal comments to NMFS, CSP called on the agency to withdraw the 2008 Vessel Speed Rule and pursue a more adaptive approach that reflects the significant advancements in vessel navigation, whale detection and real-time communication technologies available to mariners today. CSP emphasized these technologies can result in targeted risk reduction and improve conservation outcomes while maintaining safe and reliable public access to America's public waters. The full comment letter is available here.
"Technology has evolved dramatically since 2008, and conservation strategies should evolve with it," said Jeff Angers, president of the Center for Sportfishing Policy. "Today's vessel operators have access to tools that simply did not exist when the original rule was developed. NOAA now has an opportunity to pursue a more targeted and effective approach that improves whale protection while also preserving safe and reliable public access to our waters."
CSP and its partners have spent years advocating for modern, technology-focused conversations around right whale conservation and vessel strike reductions. The current ANPRM represents an important opportunity for NMFS to evaluate solutions that better reflect today's technological capabilities and operational realities on the water.
CSP's comments highlighted several key concerns with the current framework, including the lack of statutory authority underpinning the 2008 rule; the disproportionate burdens static seasonal restrictions place on recreational boating and fishing, and the need for NOAA to modernize how vessel risk is assessed.
The organization also pointed to NOAA's own findings from its 2024 North Atlantic Right Whale Vessel Strike Risk Reduction Technology Workshop, which recognized the growing capabilities of technologies such as thermal imaging, passive acoustic monitoring, AI-assisted whale detection systems, AIS-based alerts and real-time navigation integration.
CSP emphasized that its recommendations are grounded in current technological capabilities and NOAA's own findings regarding the growing role of real-time detection, communication and dynamic risk reduction tools.
"We support an outcome-oriented non-regulatory approach that promotes the use of emerging technologies and operational innovations to reduce marine mammal strike risk and improve species conservation," CSP wrote in its comments. "We encourage NOAA Fisheries to prioritize cooperative flexible management measures that result in targeted risk reduction rather than relying on static seasonal restrictions developed nearly two decades ago."
CSP further noted that future conservation efforts should encourage innovation, voluntary compliance and public-private collaboration by creating incentives for vessel operators to adopt proven technologies and operational best practices.
The organization stressed that recreational fishing and boating remain foundational components of America's outdoor recreation economy and coastal communities, supporting millions of jobs and generating significant conservation funding through excise taxes, licenses and participation.
"Protecting the North Atlantic right whale remains a shared priority," Angers said. "But static restrictions developed nearly two decades ago should not prevent NOAA from embracing the technologies and operational innovations available today to improve both conservation outcomes and public access."