IMMP Opposes Trump Efforts to Speed Ships in Whale Habitat
By Mark J. Palmer
The Trump administration is going after a speed rule that limits large vessels to a ten-knot speed limit in certain areas known to be habitat for the endangered North Atlantic right whale.
The US National Marine Fisheries Service is proposing to replace the speed zones, where ships must slow down, with a more complicated process dependent on technology that is certainly not ready for distribution, likely resulting in more ship strike losses of the whales. The population of NA right whales is only about 380, with perhaps 70 reproductive females, upon which the future of the species depends.
Here are the comments supplied by the International Marine Mammal Project of Earth Island Institute in opposition to this plan.
June 1, 2026
Ms. Kimberly Damon-Randall, Director
Office of Protected Resources
National Marine Fisheries Service
National Oceanic and Atmospheric Administration
Department of Commerce
Submitted Via https://www.regulations.gov
RE: Opposition to Proposed Amendments to North Atlantic Right Whale Vessel Strike Reduction Rule (50 CFR Part 224; Docket No. 260227–0058) (“The amendment”)
Dear Ms. Damon-Randall:
Thank you for the opportunity for the International Marine Mammal Project (IMMP) of Earth Island Institute and our Maine office to voice our opposition and comment on the proposed Amended North Atlantic Right Whale Vessel Strike Reduction Rule.
The current population of North Atlantic right whales is only 380 individuals, only a few of which are females able to bear calves every few years. Ship strikes by speeding vessels and entanglement in fishing gear are the major dangers to right whales during their migrations.
Between 2017 and 2026, 27 right whales were killed or injured because of vessel strikes. (US National Marine Fisheries Service https://www.fisheries.noaa.gov/national/marine-life-distress/2017-2026-north-atlantic-right-whale-unusual-mortality-event)
Furthermore, approximately 64% of right whale deaths from any source are never recorded. (US Marine Mammal Commission https://www.mmc.gov/priority-t...)
The Amendment Undercuts the Protection of Seriously Endangered Right Whales
The proposed amendment would change speed limits to avoid ship strikes from slowing vessels in areas deemed critical to right whales to a system vaguely involving technology meant to detect whale presence, then triggering a slowdown. The catch is that, under this scenario, the vessels must be able to detect the whales and react in real time, presumably slowing down and changing course.
While such technologies are promising, they are unable to detect every whale, given the low profile of right whales and the difficulty of detecting the whales through the noise and chaos of the marine environment.
The National Marine Fisheries Service (NMFS) should not implement any such changes to the speed rule that endanger right whales. And frankly, ANY ship strike endangers this population. The proposed modification of the rule is a prescription for extinction of the North Atlantic right whale.
The Amendment Should Extend Speed Rules Instead of Ending Them
Current speed rules set at 10 knots have been determined to be the best speed to avoid killing whales in coastal habitats.
Instead of curtailing the speed zones, the zones should be increased to include more right whale habitat where ship strikes threaten the population.
Furthermore, we believe the speed limit of 10 knots in the Designated Management Areas should be mandatory, not voluntary, when right whales are present.
An additional priority for NMFS is to get better speed compliance from ships using US ports. What is to prevent these ships from further ignoring technological means to detect the presence of whales? NMFS needs to take into account the number of vessels that ignore vessel speed limits and take action to enforce the speed limits.
Using Speed Limit Zones Is Not Incompatible with Other Technologies
There is no compelling need to remove current area speed zones to protect right whales from the proven, well-documented dangers to the species – ship strikes.
Use of technologies to identify whales in the vicinity of ships will take time to both perfect and install. Not to mention money for government subsidies to ship companies, as IMMP and our many colleagues have supported for years, to help the lobster industry in Congress and provide funding for NMFS research, stranding, and enforcement.
The speed rule amendment should be rethought, with greater emphasis on expanding protection for right whales while helping develop technologies that could, in theory, replace the speed rule.
But taking action now to reduce the speed rule protections is not just premature, but a clear case of NMFS violating the ESA for the sole purpose of benefitting the economic concerns of shippers.
Using Economic Input to Determine Protection for Endangered Species Would Violate the ESA
The Endangered Species Act (ESA) is clear that economic considerations should not weigh heavily on basic biological decisions made to safeguard an endangered species from extinction.
We believe NMFS, if they implement a rule to allow higher speeds in right whale habitat, would be a violation of the ESA and result in the extinction of the North Atlantic right whale.
In conclusion, the International Marine Mammal Project of Earth Island Institute opposes the proposed rulemaking by NMFS and urges NMFS to withdraw this proposal.
Thank you for the consideration of our views on continuing and expanding the speed rule and zones to help the North Atlantic right whale avoid extinction.
Sincerely,
David Phillips, Executive Director
Cindy Lowry, Maine Campaign Coordinator For North Atlantic Right Whales
Mark J. Palmer, Associate Director
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