THE COMMENT PERIOD ON SEISMIC BLASTING CLOSED JULY 21, 2017

THANK YOU FOR SUBMITTING YOUR COMMENTS

Information on seismic blasting:

Information from a Consortium of Scientists and the NRDC:

  • Small numbers : the Fisheries Service (NMFS) has to prove that only ‘small numbers’ of individuals from a stock/population/species of marine mammal are being taken.  There is no definition of ‘small’ but they have tried to use 30%, which is in no way small.  In any case, small numbers could not possibly be met with 5 surveys hitting the same areas and the thousands of dolphins, hundreds of right whales, etc, that will be impacted.
  • Negligible impact: NMFS has to prove that the activity will have no more than a ‘negligible impact’ on stocks or populations.  Again, this seems nearly impossible with 5 surveys being permitted, especially for right whales.
  • NMFS is still using the very outdated (both in years and scientifically) the thresholds of 160 decibel (dB) for behavioral impact and 180 dB for injury in their calculations.  We know that bowhead whales (a close cousin of the right whale) starts responding behavioral at ~100 dB or 100,000 times less than the threshold.  So, what this means if that if they were to use modern thresholds, the areas of impact would be massive, as would the numbers of animals be more massive than they are.
  • Inadequacy of mitigation:
    • There is NO baseline data for most of the species that would be impacted, so we do not know what ‘negligible’ would be, for example, because we have no baseline;
    • Time-area closures for places like Hatteras are completely arbitrary and capricious, e.g., they’re proposing July-Sept closing, but the highest density and diversity of whales and dolphins in the western North Atlantic lives there year round, including beaked whales, which are much more sensitive than many other whales;
    • The extensive use of passive acoustic monitoring (PAM) is not a good mitigation measure, the idea is that they listen for whales as a way to see if they’re there so they don’t harass them, but many whales actually stop vocalizing in the face of noise, so this is not a panacea for mitigation;
    • They do not explore alternative technologies (e.g., marine vibroseis, controlled source electromagnetic), which could be far less destructive, and have been demonstrated effective.

Information from the Marine Mammal Commission Report:

  • Scientists have found the following effects on marine mammals subject to exposure to seismic airgun blasting:
    • Behavioral changes to include avoidance of areas, changes to diving and surfacing patterns, changes to vocalization intensity, frequency, repetition and duration;
    • Physiological reactions and/or physical injury: stress and tissue injury due to intense sound exposure (found in beached beluga whales who had been subject to seismic blasts); permanent hearing loss which would leave marine mammals highly vulnerable as auditory communication is essential to their livelihood;
    • Ecological effects: loss of prey due to documented avoidance of blast areas by fish
  • Also hypothesized are effects caused by the presence of an anthropomorphic sound (like an airgun blast) causing a natural sound to be undecipherable, which can affect:
    • reproduction if a female cannot hear potential mates vocalizing,
    • mother-offspring bonding and recognition if they cannot communicate effectively,
    • foraging if animals cannot detect prey or in the case of animals that hunt cooperatively, cannot communicate, and
    • survival if an animal cannot detect predators or other threats.

Information Related to Legal Requirements Based on Permit Application and Federal Law

  • In accordance with federal law cited in the federal register notice, “An authorization for incidental takings shall be granted if National Marine Fisheries Service finds that the taking will have a negligible impact on the species or stock(s). . . [where] ‘negligible impact’ has been defined by NMFS as ‘an impact . . .that cannot be reasonably expected to, and is not reasonably likely to, adversely affect the species or stock through effects on annual rates of recruitment or survival.'”
    • While scientific data on the effects to marine mammals has been gathered, not enough research has been done to determine whether the taking would indeed be “negligible” under NMFS requirements; therefore, in accordance with federal law, these permits should be denied.
  • Marine Mammal Protection Act requires that petitioners identify ways to reduce impacts to the “lowest level practicable.”
    •  There are new, cheaper technologies available for surveying these areas, and
    • One study could suffice, rather than allowing 5 separate vessels to crisscross these delicate habitats blasting every 10 seconds, 24 hours a day for up to 300 days out of the year;
      • Therefore, in accordance with federal law, these permits should be denied.
  • The Endangered Species Act (ESA) prohibits harm to species threatened with extinction, including 16 cetacean species, and requires conservation of their habitat;
    • Therefore, in accordance with federal law, these permits should be denied:
      • The critically endangered North Atlantic Right Whale’s only habitat is the mid and south Atlantic Ocean.
      • Other endangered marine mammals in blasting area include:
        • Fin whales, blue whales, sei whales, sperm whales

Information from the Southern Environmental Law Center (SELC)

  • Studies have shown that seismic testing could potentially harm commercially valuable fisheries by decreasing catch rates by as much as 80% percent.  This can affect marine mammals who prey on these species. Additionally, that’s a big blow to commercial and recreational fishing, which is central to the economies of towns and cities along the Southeast coast. Just imagine the impact on our coasts if valuable fish populations were decimated by this activity.
  • The Department of the Interior estimates that more than 130,000 marine mammals, including endangered species like North Atlantic right whales, will be injured by seismic testing along the East Coast.
  • In addition, seismic testing carries the harm to our ocean, including to marine mammals, without providing precise information. Shell’s decision to pull out of the Arctic after a $7-billion investment was due in part to drilling yielding no oil after seismic testing indicated it would. Even industry sources admit that the only thing that truly identifies oil and gas reservoirs is drilling.
    • To definitively know how much oil is available, companies need to drill exploratory wells. Exploratory drilling is the riskiest offshore oil activity and what was taking place when the BP Deepwater Horizon spill in the Gulf occurred.
  • An overwhelming number of communities along the Southeast coast have spoken out to protect our economy, environment (including marine mammals), and way of life from oil and gas drilling. Seismic is the first step in this process, and could do substantial harm to our oceans, (including marine mammals) before the oil and gas companies move in.
  • We cannot allow seismic testing off our coasts.