Date: 30 March 2023

Under Appendix I notifiable events, 

Under 5 bis, notifiable marine mammal issues should not be limited to fatalities or marine mammals in evident distress; any effects on marine mammals or their behaviour would need to be notifiable; and we support the US that this should not be limited to marine mammals but would need to apply other fauna.

Under item 10.    Adverse environmental conditions with likely significant safety and/or environmental consequences [such as serious harm] needs addressing.

The list of adverse and potential environmental consequences of any DSM is far broader, more open ended and unknowable than is expressed here.

Firstly, the term  significant is problematic.

Secondly, The term serious harm is too high a threshold.  Any environmental harm should be notifiable.

And thirdly the term “adverse environmental conditions” is vague. We would need to include ‘situations, issues, and consequences.’

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