NMMA Comments to NOAA Reinforce Incorporating Technology in Rulemaking

NMMA strongly supports science-based efforts to protect the North Atlantic right whale and the marine ecosystems that sustain boating, fishing, and coastal communities. In its comments, NMMA emphasized that conservation and access can, and must, work together. The recreational boating community has a long track record of working with NOAA and other federal partners to support healthy marine resources while ensuring Americans can safely and responsibly access public waters.

Related: NOAA Reopens North Atlantic Right Whale Vessel Speed Rule for Public Input

The current rule was first issued in 2008 and applies a 10-knot speed restriction to vessels 65 feet or greater in certain seasonal management areas along the East Coast. At the time, NOAA acknowledged there was limited data supporting the effectiveness of the rule, and the original regulation included a five-year sunset provision. NMMA's comments urge NOAA to take this opportunity to fully reevaluate the rule's underlying assumptions, including its effectiveness, safety impacts, economic impacts, and ability to reflect modern technology.

Since 2008, marine technology has advanced significantly. NMMA's comments highlight tools such as passive acoustic monitoring, aerial surveys, thermal imaging, satellite imagery, radar, LIDAR, artificial intelligence, real-time navigation alerts, and electronic charting systems. When used together, these tools can help detect whales, share information with mariners, and support more precise, real-time decision-making on the water.

NMMA also pointed to the work of the Whale and Vessel Safety Task Force, or WAVS, which brings together boat manufacturers, marine electronics companies, software developers, boat builders, engine manufacturers, vessel operators, and detection technology experts to identify and test tools that can reduce vessel strike risk. This industry-led work shows that the recreational boating sector is not waiting on the sidelines. The industry is helping develop practical solutions that can protect whales, support mariner safety, and preserve access to the water.

The comments also call on NOAA to move away from broad, static speed restrictions and toward a modern, technology-driven, dynamic management approach. Seasonal speed zones are based largely on historical patterns. By contrast, dynamic tools can help identify where whales are actually present and provide timely information to mariners. NMMA emphasized that this type of approach can improve conservation outcomes while reducing unnecessary burdens on boaters, anglers, manufacturers, marinas, charter operators, and coastal businesses.

Related: NMMA Applauds Withdrawal of Vessel Speed Reduction Rule; Encourages Technology-Centered Durable Solution for Marine Mammal Protection

NMMA further urged NOAA to fully account for the rule's economic impacts. Recreational boating generates $230 billion in annual economic activity, supports more than 812,000 jobs, and includes more than 36,000 businesses. Approximately 93 percent of boat builders and suppliers are small businesses. NMMA's comments make clear that vessel speed restrictions do not simply add travel time; they can deter boating and fishing trips, raise safety concerns, and harm the coastal economies that depend on boating access.

Mariner safety is another central concern. NMMA's comments explain that safe operating speed depends on vessel size, hull design, weather, sea state, visibility, and the operator's ability to respond to changing conditions. For many recreational vessels, especially smaller planing vessels, forced low-speed operation can reduce maneuverability and create safety risks in certain offshore conditions. NMMA encouraged NOAA to better account for these vessel-size-specific safety considerations as it reviews the rule.

NMMA also encouraged NOAA to pursue an education-forward approach that gives mariners the tools, information, and awareness needed to reduce risk on the water. This includes stronger collaboration among NOAA, the U.S. Coast Guard, the recreational boating industry, marine electronics manufacturers, and other stakeholders.

"Protecting the endangered North Atlantic right whale is a shared priority, and NMMA believes the best path forward is one that reflects the technology, data, and real-world boating conditions of today," said NMMA. "A modernized rule should support conservation, preserve mariner safety, and protect access to public waters."

As NOAA considers updates to the Vessel Strike Reduction Rule, NMMA will continue to advocate for a durable, science-based framework that advances conservation while supporting recreational boating, coastal communities, and America's marine manufacturing sector.