Comment from Anderson, Samuel
Samuel AndersonSupportIndividual
Summary: The commenter supports the issuance of the incidental take regulation but requests a modification to the reporting requirements. They argue that the Service should require independent third-party observers to report takes to avoid potential conflicts of interest and ensure data credibility.
I support issuing this incidental take regulation; however, I would urge the Service to change the reporting method of said takes. The current proposal relies on reports from SAExploration's bear guards, rather than an independent third-party with no interest tied to the reporting. The on-site monitoring data is the main check on whether a take falls under the limit set by the Service, but under the proposed rule this data would be created and reported by the actual party being regulated. This creates a concern for conflict of interest because reporting a take near to the limit or over the limit would result in work stoppages and additional liability for SAExploration. The Service's rejection of third-party observers was based on the "inherent safety considerations," but that incentive only extends to personnel watching for bears in order to stay safe, not ensuring that each take is accurately recorded and reported. Independent observers are a standard when it comes to marine mammal authorizations, and requiring them in this case would strengthen the credibility of reported data while also allowing SAE's activities to continue.
35125 (For Dr. Klingler)