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Introduction
The National Marine Fisheries Service (NMFS) issued an advanced notice of proposed rulemaking (ANPRM) seeking to amend the North Atlantic Right Whale (NARW) vessel strike reduction rule. The ANPRM specifically seeks information regarding the efficacy of the existing rule, as well as potential changes to the geographic scope, vessel size thresholds, and alternative enforcement mechanisms. This comment addresses several of these areas and how they might be important for future NARW rulemakings. Our conclusions are as follows. First, our evaluation finds that the economic impacts of the rule have been blunted by low compliance rates. Nonetheless, the initial analysis omitted several key market and nonmarket welfare effects that ought to be considered in future rulemakings. Second, the spatial boundaries of the speed zones are less congruent with the NARW habitat compared to when the rule was originally proposed in 2008, requiring a more dynamic approach to setting spatial boundaries. Third, public-private partnerships have been arising in the US and elsewhere to make better use of remote sensing data to identify and alert mariners of whales and other marine mammals in the area to avoid a ship strike. These technologies, coupled with the use of more dynamic habitat management techniques, could improve NARW conservation efforts.