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WDCS letter on the Port Access Route Study

Docket Management Facility (M–30)
U.S. Department of Transportation,
West Building Ground Floor, Room W12–140
1200 New Jersey Avenue SE.
Washington, DC 20590–0001.

31 January 2012

Dear Sir or Madam:

On behalf of the supporters and constituents of the Whale and Dolphin Conservation Society (WDCS), I would like to offer the following comments regarding Port Access Route Study: The Atlantic Coast From Maine to Florida docket number USCG– 2011–0351.

WDCS appreciates the efforts of the USCG to “reopen the comment period to seek more information to ensure that the PARS is comprehensive in its data collection and analysis”. It is in that respect that we offer our comments and request that impacts to large whales, with special attention to the endangered North Atlantic (NA) right whale (Eubalaena glacialis), be considered in this PARS.

As you are aware, vessel strikes are a leading cause of serious injury and mortality for the critically endangered NA right whale. The IMO has authorized specific modifications to shipping routes and created Areas to be Avoided in the US and Canada for NA right whales. In addition, the US has instituted a seasonal ship speed rule specific to reduce risk to this species.

(1) How are your ocean going vessel coastwise routes affected by seasonal or episodic weather variations?

(2) How are your near coastal tug and barge routes affected by seasonal or episodic weather variations?

According to NOAA, the distribution of marine species and populations will change with respect to changes in climate and weather conditions1. The NA right whale feeds exclusively on zooplankton, the location and density of which relies on weather and climate patterns. Research demonstrates that Calanus copepods, the primary prey source for NA right whales, are retreating northward2. These shifts in distribution must be considered when evaluating shipping routes to ensure that the risk of vessel strikes is not increased for this species.

(3) Is there a regularly scheduled recreational event that uses the near coastal waters in your area?

Recreational events would include offshore fishing tournaments, offshore power boat races, offshore sailing regattas, etc. We suggest that the USCG give special consideration to all areas where whale watch operations occur. Commercial whale watch activities are emblematic of areas where whale species congregate spatially and temporally and, therefore, a risk of vessel strikes must be considered.

(4) Do you regularly transit the near coastal area on recreational/private yachts? If yes, how far offshore is your typical route? Does your route change seasonally or according to weather conditions?

WDCS does transit the coastal waters of the Gulf of Maine on a private vessel. We are typically within 20 miles of port. Changes in our transit area are a result of the likelihood of encountering large whales during their feeding season. However, substantial documentation exists to demonstrate that some right whales remain in the Gulf of Maine year round while others migrate to the Southeast US during the winter to mate and calve3. Furthermore, the risk of vessel strikes is as high, or possibly higher, in the mid‐Atlantic, an area through which these whales migrate4. Reported numbers of vessel strikes represent a minimum as most strikes go unreported and not all carcasses are retrieved for necropsy. As a result, we suggest that, for this species in particular, a broad seasonal distribution must be considered.

(5) Should coastwise routes be established along the Atlantic Seaboard similar to the ‘‘M–95’’ marine highway corridor designated by the Maritime Administration as part of ‘‘America’s Marine Highway Program’’? For more information on this program, see America’s Marine Highway Program— Report to Congress—April 2011( MARAD_AMH_Report_to_Congress.pdf). If yes, where should they be located?

We would like to point out that in the report to Congress, there is no consideration of potential impacts to marinemammals or the risk of vessel strikes. As a result, we cannot support the establishment of increased coast‐wide shipping as outlined by the “America’s Marine Highway Program.”

(6) What are the pros and cons to the Coast Guard designating coastwise fairways or traffic separation schemes (TSSs)?

While we do not dispute that there may be advantages to coastwise fairways for economic reasons, we are concerned about the increasing risk of ship strikes to large whales. The Boston TSS lanes were specifically narrowed by 0.5 miles and shifted 12 degrees to reduce the risk of vessel strikes to large whales. In the Great South Channel a seasonal area to be avoided (ATBA) was established to reduce the risk of strikes to NA right whales. Any further designation of TSSs or coastwise fairways must consider the risk posed to endangered large whales.

(7) Could the creation of designated coastwise routes adversely impact watch standing or other operational requirements? If so, please explain

We offer no comment regarding vessel watch implications.

(8) If coastwise fairways were created, should separate fairways be created for different vessel types such as tug and barge vs. deep draft vessels?

We believe that fairways should consider vessel speed as well as vessel size. Data show that vessels transiting at 10kts or less substantially reduce the risk of mortality in the event of whale is struck

(9) Should there be separate lanes for vessels traveling in opposing directions?

While we do not offer advice on the direction of travel, we do recommend that, in areas where whales are known to occur, TSS lanes are as narrow as possible while still allowing for navigational safety. The 0.5 mile narrowing of each lane of the Boston TSS allows for vessels to safely transit while, at the same time, reducing the likelihood of overlap with large whales by 11%7.

(10) Should participation in any coastwise traffic scheme be voluntary or mandatory for all or certain classes of vessels?

We respect that vessel operations must first and foremost consider the safety of the vessel and its passengers. However, regulatory measures are more likely to be adhered to as compared to voluntary measures. AIS data demonstrates that ships are more likely to reduce speed in seasonally managed areas, which are regulated, as compared to Dynamic Management Areas which are voluntary.

(11) Given the potentially long transit times, varying sea state and weather conditions; what is an appropriate width for fairways to prevent degradation to navigational safety? Are there particular areas where the width could be smaller or should be larger?

Based on the success of the narrowing of the TSS off Boston, we would suggest that a 1.5 mile lane size be considered as a maximum for any further TSS considerations. We acknowledge and support that vessel safety must be prioritized. At the same time, potential impacts to endangered large whales must be included.

Thank you for the opportunity to comment on this important issue.


Regina Asmutis‐Silvia
Senior Biologist
Master 100 GT
Whale and Dolphin Conservation Society
7 Nelson Street
Plymouth, MA 02360