Response to Comments on Level A Form

Response to Public Comments (received comments from 3 members of the public):
1. Two comments recommended removing the check box related unusual mortality
events on the Marine Mammal Stranding Report Form - Level A. We agree and have
done so. This information will be documented by the NMFS regional stranding
coordinator on the Level A data sheet and/or National Marine Mammal Stranding
Database in a special designated field labeled Group Events.
2. Three comments recommended defining the term “limited” and “complete”
necropsy that is listed on both of the forms – Marine Mammal Stranding Report
Form – Level A and the Marine Mammal Rehabilitation Disposition Form. We
agree and will provide definitions in the accompanying Examiner’s Guide to be
distributed to the Stranding Network. Briefly, a “complete necropsy” is any
necropsy where the majority of organs are collected according to established
protocols and a “limited necropsy” is any necropsy where either the condition of
the animal or other factors limit a complete necropsy. We also added the terms
under this section “carcass fresh” and “carcass frozen/thawed” to better
establish the condition of the specimen upon the time of necropsy.
3. A comment was made inquiring about the interpretation of “whole carcass” vs.
“partial carcass” under the section entitled Morphometric Data on the Marine
Mammal Stranding Report Form - Level A. These terms will further be defined in
the accompanying Examiner’s Guide to be distributed to the Stranding Network.
Briefly , these terms do relate to length measurements to document whether there
the carcass was complete and intact or only a partial specimen was available for
measurement.
4. A comment was made inquiring about the definition of the term “Stranding
Agreement or Authority” that is used on both forms. This term will further be
defined in the accompanying Examiner’s Guide to be distributed to the Stranding
Network. Briefly, this term refers to the Stranding Agreement holder or agency
through which the examiner has been authorized to take marine mammals or
marine mammal parts. If the examiner is a member of a Designee Organization,
this refers to the name of the Stranding Agreement holder under whom the
examiners organization is designated.
5. A comment was made for clarification of the term “Age Class” that is used on
both forms. Terms for adult, subadult, yearling, and pup/calf will be defined in
the accompanying Examiner’s Guide to be distributed to the Stranding Network.
More detailed information regarding species specific age determination can be
found in the literature.
6. A recommendation was made to include documenting if post release
biomonitoring was carried out, disposition of this information, and specific details
including type of tag, size, expected duration, etc. We agree and added this to the
Tag Data field in the Marine Mammal Rehabilitation Disposition form. We

consider specific details about the tag beyond Level A data but they could be obtained
through a point of contact (i.e., data disposition). We will include this instruction
in the Examiner’s Guide to be distributed to the Stranding Network.
7. A recommendation was made to include documenting where a completed Human
Interaction Data Sheet was completed on the Marine Mammal Stranding Report
Form - Level A. At this time, NMFS does not have an OMB approved form for
these data so we will include this in the form. We anticipate developing a form
for capturing these data in the near future.
8. A comment was made to delete detailed information on the Marine Mammal
Stranding Report - Level A form regarding date and facility if an animal is
transferred to rehabilitation. At this time, we feel that this information in
important to capture on both forms for consistency and will not make the
recommended change.
9. A comment was made to include a description on the Marine Mammal Stranding
Report Form - Level A under Tag Data of marking an animal if it had been
examined and left at the site. We believe that this can be conveyed in the
accompanying Examiner’s Guide to be distributed to the Stranding Network
without making a change on the Marine Mammal Stranding Report – Level A
Form.
10. A comment was made to expand the information regarding Sample and Specimen
Disposition field in the Marine Mammal Rehabilitation Disposition form. We are
in the process of completing a field on our National Marine mammal Stranding
Database to capture this information which will be more user friendly than
documenting these data by hand.
11. A comment was made to include on the Marine Rehabilitation Disposition form if
the attending veterinarian had signed off on the release recommendation and the
last day of medication (in addition to antibiotics). We agree and are in the
process of developing a health certificate that will capture this information. This
will require PRA and OMB clearance. In the meantime, we are currently
satisfied with the section capturing information on “health release screen” and
last day of antibiotic administration.
12. A comment was made regarding the information in the FRN on the total annual
cost to the public being under estimated. We agree that this value is under estimated
and have increased it to $2,448. This value represents not the cost of labor to
collect the data but the actual costs associated with capital/start up (e.g. for
electronic equipment) and recordkeeping/reporting costs (i.e., photocopying,
notarization if applicable, phone calls if not toll-free or local, postage and/or fax
costs). Our goal is to completely transition this process over to electronic data
collection. We anticipate this occurring in three years and thus will include the
costs of computers. However at this time, we have not mandated that these data

are submitted to NMFS electronically. We receive data in all forms (i.e., hand
written and electronic).
13. A comment was made disagreeing with our estimation of time per response of 30
minutes as referenced in the FRN. We increased this value from the last
submission and believe this to be an average time to fill out these forms. We
acknowledge that there is a range depending on expertise of an individual. Also,
this estimation is not based on the time to collect the actual data.