The Maritime Exchange for the Delaware River and Bay appreciates the opportunity to comment on this important topic. As information, the Maritime Exchange is a nonprofit association representing the interests of nearly 300 individuals and port-related businesses in the tristate region. Our members are keenly concerned with port efficiency, safety, security, and environmental stewardship.

The Exchange supports all reasonable measures to protect the health of marine wildlife, including the North Atlantic Right Whale. However, NOAA’s latest proposal to drastically revise the NARW Vessel Strike Reduction rule would impose severe limitations on the daily operations of port terminals and mariners throughout the Delaware River port complex and have negative effects resulting in costly and potentially hazardous outcomes. 

Approximately 2,400 vessels arrive at Delaware River ports each year, hauling nearly 60 million tons of cargo, creating approximately $50 billion of economic activity—including $1.8 billion in state and local taxes—and supporting over 155,000 direct, indirect, induced, and related jobs in the region. Any disruption to efficient port operations therefore has dramatic economic ramifications for the region.