Public Comments

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Adrienne Thomas
NOAA PRA Officer

[email protected]
June 16, 2026
Re: Reporting Requirements for Commercial Fisheries Authorization Under Section 118 of the
Marine Mammal Protection Act OMB Control Number 0648-0292

Dear Ms. Thomas,
Please consider these comments submitted on behalf of Whale and Dolphin Conservation, Inc.
(WDC), Conservation Law Foundation (CLF), and their thousands of members and supporters.
WDC is federally appointed to the Atlantic Large Whale, Atlantic Trawl Gear, Harbor Porpoise,
Bottlenose Dolphin, and Pelagic Longline Take Reduction Teams (TRTs). Staff at Conservation
Law Foundation is appointed to the Atlantic Large Whale TRT. The data provided through the
Marine Ammal Authorization Program’s Mortality / Injury Reporting Form is not only legally
required but provides essential information on marine mammal bycatch enabling TRTs to more
effectively recommend temporal and spatial risk reduction measures which reduce widescale
impacts and unnecessary regulatory burdens on commercial fisheries.
While we cannot comment on the accuracy of the cost of burden of the data collection itself, we
reiterate that the collection of these data are mandated under Section 118 of the Marine
Mammal Protection Act (MMPA) and that costs associated with the collection may be reduced
through improved methods of electronic data collection.
First, the data collection may be enhanced as well as the reporting burdens reduced by
developing an easy-to-use app that can be downloaded on android or iOS systems. If possible,
the app could temporarily store data and upload it to a cloud-based system when the reporter
was within cell phone range, reducing the burden on vessels which may not be equipped with
satellite transmissions. As most apps will store information including the vessel owner, permit
number, address, emails, etc., it would reduce the need for this information to be repeatedly
provided as is currently required. An app could also provide a connection to a camera and
provide an image of the animal which would improve data accuracy through confirming species
and/or reported injuries. Meta data stored in the image could be used to verify the date and
time of the take and the app could include GPS capabilities to automatically provide a location
when the app is in use.
In addition, more specific data should be collected to help evaluate the potential impacts on the
animals and provide more context for mitigation recommendations. For example, it would be
helpful to know whether animals were seen prior to setting or retrieving gear. While the current
codes request information on injury status (i.e. loss or damage to appendage, laceration,

eyeball rupture, etc) there is currently no means to provide information on which part of the
gear may have caused the injury, whether the gear remained on the animal during the retrieval,
if the gear was cut from the animal, and/or if the animal was released still entangled in gear.
Even for codes regarding injury, additional information as to what body part was involved that
was cut resulting in blood flow, where on the body the laceration was located, or more
information on “other wound or injury” could help identify how an animal may be interacting
with gear.
It would also be helpful for information to be provided as to how an animal was released and
the behavior of those animals upon release to better evaluate techniques that could improve
survivability of live bycaught animals.
Thank you for the opportunity to comment,

Regina Asmutis-Silvia
Executive Director
Whale and Dolphin Conservation
[email protected]

Erica Fuller
Senior Counsel
Conservation Law Foundation
[email protected]