Comment from Furjan, Nastasija

The North Atlantic right whale is an incredible species that belongs in our ocean, but is unfortunately at risk of extinction. Vessel strikes are often lethal and a main threat to the survival of the species. The North Atlantic right whale vessel speed rule, which has been in place since 2008, has been critical to keeping North Atlantic right whales alive. An abundance of peer-reviewed scientific analysis, including analysis from the National Oceanic Atmospheric Administration (NOAA) and agency affiliated scientists, has shown that vessel speed rules work to protect whales and has shown that voluntary vessel speed limit approaches are insufficient to reduce the risk of vessel strike-related mortality for whales (Compliance with vessel speed restrictions to protect North Atlantic right whales DOI:10.7717/peerj.399; Estimating reductions in the risk of vessels striking whales achieved by management strategies DOI:10.1016/j.biocon.2023.110427; Estimating reductions in the risk of vessels striking whales achieved by management strategies DOI:10.1016/j.biocon.2023.110427). NOAAs own assessment of the vessel speed rule published in June 2020 found that continued speed restrictions are warranted and recommended that the rule be strengthened. Vessel speed rules for North Atlantic right whales must not be replaced with technology. A NOAA commissioned report showed that many of the proposed technologies are not viable, have not been tested on whales, and do not meet the scoring criteria for detection. Technology may help identify whale presence, but it is only a diagnostic aid. A vessel speed rule is what actually solves the problem by reducing the likelihood of lethal vessel strikes. Even the most advanced tools still have significant limitations and cannot replace strong, enforceable protections. Technology can complement the vessel speed rule, but it cannot substitute for it.