45 



VIII. CONCLUSIONS/RECOMMENDATIONS 



Let's not compromise such a positive program as whale watching by simpUfying 

 guideUnes to a nationaJ standard; especially when there isn't any scientific basis to 

 support this standard, and we're not the problem. 



We recommend that the regional whale watching regulations or guidelines cur- 

 rently in place be managed by the NMFS regional directors. Trust them, and us to 

 work together, to manage and enforce marine mammal protection. 



We urge the various govenmient agencies to work together to increase public 

 awareness and support for marine mammals through the following methods: 



• Have the USCG Auxiliary add whale watching guidelines to their "Safe Boating 

 Classes." 



• Have the regional whale watch guidelines included when privateboaters reg- 

 ister their boats with the USCG each year. 



• Work to improve communication with the NMFS and the USCG to increase en- 

 forcement and response time to whale entanglements from commercial fishing gear. 



The NEWWA looks forward to working with you„NMFS, and the USCG to sup- 

 port the MMPA, and to educate the public at large about marine mammal protec- 

 tion. Let's not make changes for the sake of legal simplicity, or due to some political 

 Eressure. We urge the committee to look at the big picture, and for what is really 

 est for the marine mammals. 



NORTHEAST WHALE WATCHING ASSOCIATION MISSION STATEMENT 



To foster an appreciation of cetaceans and their natural habitat. To increase pub- 

 lic awareness about the need to protect whales and their habitat, through edu- 

 cational whale watching. 



To work with State and national government and agencies to further increase 

 public knowledge and understanding of marine mammals, while encouraging re- 

 search to support whale watching guidelines, or modifications as needed. NEWWA 

 also supports the active enforcement of responsible whale watching guidelines for 

 its region. 



To provide a pro-active voice for whale watching in the Northeastern United 

 States, through shared knowledge with NEWWA's members on new developments 

 in local, national, and international issues pertaining to whale watching, the envi- 

 ronment, and legislative changes. 



letter from biuan macdonald, associate director, new england aquarium 



November 11, 1992. 



Dr. Nancy Foster, 



National Marine Fisheries Service, 



Silver Spring, MD 20910 



Dear Dr. Foster: This letter is written in response to the proposed regulations 

 to govern approaches to marine mammals (Fed.Register. Vol. 57, No. 149). u is writ- 

 ten on behalf of the Northeast Whale Watching Association (NEWWA), which is 

 comprised of members from the whale watching industry: privately-owned whale 

 watching companies, naturalists, research scientists, and educational and research 

 institutions. 



Although we certainly support the Office of Protected Species' efforts to aid in the 

 recovery of endangered marme mammals, we strongly disagree in three key areas 

 as discussed below. 



• First, we disagree with the summarized conclusions that were derived from the 

 Monterey Workshop. Our consensus of the meeting was quite the contrary. 



• Second, the subjective editing of references in the Environmental Assessment, 

 and the background information in the Federal Register do not accurately reflect the 

 scientific research cited, and it omits information that is relevant to the field. 



• A third and fundamental concern we have, is that the focus on marine mammal 

 approach guidelines is being addressed as the primary threat to the recovery of 

 wnale populations, when impacts from other critical factors are ignored (e.g. com- 

 mercial fishing, tankers). The scientific evidence does flat support this negative 

 claim about wnalewatching, and NMFS has not provided one study on the effects 

 of whalewatching since it was recommended by the attendees of the 1988 workshop. 



/. Monterey Workshop, Nov. 1988: Many of the members of NEWWA were present 

 and actively participated in the workshop (Nov. 1988-Monterey, CA) referred to in 

 the Environmental Assessment to Govern the Approaches to Marine Mammals. The 

 workshop did bring together knowledgeable representatives of the whale watching 



