Editor’s Note: These commnets were originally filed in April, 2011. They are being reproduced to add to the body of scientific information presented in this Interactive Public Docket. dealing with the harmonization of seismic regulation.
UNEP is meeting within the next two weeks on a draft report dealing with the impact of noise on marine mammals.
CRE Brazil is not aware of any request by UNEP for comments from the public on the current version of the report although they might have made done so on an earlier version.
In that UNEP consists of nearly 200 countries throughout the world a publication by UNEP could have a long and lasting impact on public policy.
CRE Brazil concludes that the report is highly inaccurate in that it does not reflect the current state of science dealing with noise and its impact on marine mammals.
The attached document prepared by CRE Brazil highlights a number of shortcomings in the report, including:
The Noise Report Does Not Accurately Describe Current Science On The Effects of Anthropogenic Sound on Ocean Life
The Noise Report takes the position that a precautionary principle should be applied to regulating ocean sound because there is so much uncertainty about the effects of ocean sound.
The positions set forth in the Noise Report are inconsistent with the growing body of evidence discussed in various regulatory risk assessments for ocean sound, including those produced by the U.S. Department of the Interior and NOAA/NMFS. These risk assessments correctly conclude that, under the long-standing regulation criticized by the Noise Report, cetacean and pinniped stocks are growing concurrent with decades of oil and gas seismic and other sound-producing operations. The Noise Report does not mention these risk assessments, which show that there is no basis for the Report’s recommended excessive precaution and over-regulation. There is no basis for questioning current regulatory requirements because the record shows they are the working.
Despite its criticism of current regulatory requirements, the Noise Report does not and cannot cite a single study that has found a population level change in marine mammals caused by exposure to anthropogenic sound from seismic operations.
See the attachments below; stakeholders and the public are encouraged to submit comments.