July 26, 2024 

Ms. Kimberly Cole
Delaware Coastal Programs
100 W. Water Street, Suite 7B
Dover, DE 19904 

Re: NMFS Whale Collision Speed Reduction (2024.0036)

Dear Ms. Cole: 

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.

(see attachment for full letter)