To: Ms. Kelie Moore, Federal Consistency Coordinator, Georgia Department of Natural Resources
Dear Ms. Moore,
I write to express my support for the National Oceanic and Atmospheric Administration (NOAA)’s proposed expansion of a 2008
vessel speed rule. This proposed rule has been thoroughly studied by NOAA and subject to extensive public review. It is not inconsistent with Georgia’s coastal policies and regulations. Most importantly, the expanded rule is urgently needed to help ensure the survival of Georgia's state marine mammal, the critically endangered North Atlantic right whale.
I stand alongside thousands of other Georgians who care deeply about our coastal way of life and have a long legacy of working collaboratively to protect our wildlife. We understand that we do not have to choose between our economy and protecting these beloved animals. Indeed, many of us choose to live and vacation here precisely because of our iconic species, like right whales. We are proud that our coast plays a singular role in the life history of this majestic species, as its only known calving ground in the world.
With fewer than 360 North Atlantic right whales left on the planet, we must take immediate and drastic action if we want to save them from extinction. Leading right whale scientists tell us we cannot afford to lose a single more whale per year to human causes; yet during the recent 2024 calving season alone, four whales—a reproductive female, a juvenile female, and two newborn calves—were killed or seriously injured by vessel strikes in Southeastern U.S. waters. These recent mortalities, along with other documented deaths in recent years, are killing these animals faster than they can reproduce to save their species.
According to data from NOAA and Georgia DNR, since the existing vessel speed rule was first implemented in 2008, the number of right whales killed by large vessels over 65 feet in the U.S. immediately declined, while the number of mortalities from those 65 feet or less did not. The data is clear: too many whales are still being struck and killed by these smaller vessels.
As we continue this discussion, it is important that we all recognize a few facts. First, the proposed expanded rule will require reduced speeds for only a very small percentage of yachts and large vessels during a few months of the year here in coastal Georgia. Further, these semi-truck sized whales, which can top 50 tons, pose significant safety risks to humans. Fast moving vessels simply cannot see them before it is too late, leading to potentially catastrophic consequences for the whale, vessel, and everyone in the water during a collision. Moreover, human safety is literally baked into the rule itself, as updated safety provisions allow vessels to exceed the 10-knot restriction in circumstances where human health and safety are at risk.
There are currently NO existing technologies that can replace the need for the vessel speed rule. While there are a range of technologies in development that may someday be able to help track whales and alert boaters, they are not tested or as effective in reducing the risk of a fatal strike as a 10-knot vessel speed restriction. Technological solutions will likely never be able to fully replace vessel speed regulations to protect whales. Reducing vessel speed to 10 knots is scientifically proven to reduce the risk of mortality from a collision by up to 90% and is a widely accepted international measure for marine mammal conservation.
Finally, as you prepare your response to NOAA, we urge you to listen to and learn from the experienced wildlife biologists within your own agency, who uniquely understand our whales and the scientific data that demonstrates the need for this vessel speed rule. Georgia has always been a leader for North Atlantic right whale conservation, and the species biologists with Georgia DNR’s Wildlife Resources Division regularly put their lives on the line to monitor and rescue these animals. They can provide the necessary expertise and data to inform your position.
Thank you for considering my comments, and for the work you do to protect our coast and its wildlife. We encourage you to submit your consistency determination letter supporting the expanded rule to NOAA as soon as possible, in hopes that
this safe and effective rule will be finalized before next calving season—and before any further preventable deaths for this beloved species.
Sincerely,
Faustina Smith
Savannah, GA
United States
CC: Doug Haymans, GA DNR — Coastal Resources Director
Ted Will, GA DNR — Wildlife Resources Director
Walter Rabon, GA DNR Commissioner
Senator Raphael Warnock
Senator Jon Ossoff
Representative Buddy Carter
