How to communicate with a threatened agency?

We’ve arrived at an odd inflection point that has arisen now that National Oceanographic and Atmospheric Administration (NOAA) is on the DOGE chopping block.

In June of 2024 we submitted our comments on the 5 year review of the marine mammal noise exposure guidelines. Every five years Federal Regulations administered by NOAA need to be reviewed and revised to reflect the “Best Available Science.” This makes sense because science is all about advancing inquiry, and the ongoing results by definition are dynamic. For example; the first cut of the guidelines didn’t consider the various hearing sensitivities of regulated animals, so when dolphins were riding the bow-waves of seismic survey vessels – clearly being exposed to noise exceeding regulatory thresholds, it was evident that something was missing.

In 2007, Brandon Southall et al published a paper that suggested that the regulatory guidelines be informed by the hearing regimes of the various taxa of marine mammals – at least the cetaceans and pinnipeds (otters and polar bears didn’t make the cut). His suggestion was to divide marine mammals into frequency sensitivity bands, and in the case of the pinnipeds, incorporate amplitude sensitivity as well, so that exposure impacts could be more accurately represented in the guidelines.

Ever at the top of their game, NOAA Fisheries (National Marine Fisheries Service – NMFS) only took about eight years to reflect these data (although even then there was a bit of a bar-fight between OCR and the Seismic Survey industry on the low frequency roll-off characteristics).

Those who have been following us know that we have been trying to push “signal kurtosis” characteristics into the exposure metrics for close to 20 years now. And after synthesizing our 2024 critique, NMFS failed again to incorporate the term – although this was this first time the word appeared in the document (“NMFS also is aware that kurtosis might be a valuable metric to help move toward a quantitative means of defining whether a sound is impulsive or not”).

Kurtosis is a term that has been incorporated into Occupational Safety workplace exposure metrics for 40 years, and has lots of science that supports applying it to other mammal noise exposures – particularly chinchillas, thousands of which have been sacrificed at the altar of understanding kurtosis.

So at this point I am rather livid, which I made clear in my response to the “2024 Acoustical Guidelines Revisions.” But before I submitted our response, the chainsaws and wrecking balls arrived, which paused my submission.

We are submitting our response anyway as a matter of record. But given the deliberate chaos being generated by the current administration, the folks I am addressing probably have other things on their minds. And at this point it is hard to tell whether our letter would just be buried on some server owned by the Weather Channel.