On January 26, 2011, the U.S. National Marine Fisheries Service published Federal Register notice that NMFS has issued a letter of authorization to the U.S. Navy to take marine mammals incidental to Navy training, maintenance, and research, development, testing, and evaluation activities to be conducted within the Atlantic Fleet Active Sonar Training Study Area for the period of January 22, 2011, through January 21, 2012. This LOA is issued under the Marine Mammal Protection Act.
This is the third CRE article about comments filed on the National Science Foundation’s draft Programmatic Environmental Impact Statement (“DPEIS”) for NSF’s offshore and overseas seismic activities. This third article discusses comments on the use of the so-called Southall Criteria to regulate seismic.
We believe that any significant change from the seismic regulation now required in the Gulf of Mexico is unnecessary to protect marine mammals or other species. We also believe that any significant change (e.g., required use of acoustic models) would significantly increase the expense, delay, burden and uncertainty of seismic exploration. There is no evidence of a problem sufficient to justify this increase in expense, delay, burden and uncertainty.
This is the second article CRE has written about comments filed on the National Science Foundation’s draft Programmatic Environmental Impact Statement (“DPEIS”) for NSF’s offshore and overseas seismic activities. This second article discusses comments on the regulatory metric that U.S. agencies use to regulate seismic.
We are writing these articles in part because CRE has been asked by several Congressional committees to advise them on possible job-killing rules. CRE’s Letter to Cong. Issa in response to one of these inquiries is attached as Appendix A to this article. An InsideEPA article on the letter is attached as Appendix B.
The Center for Regulatory Effectiveness recently filed comments on the National Science Foundation’s draft Programmatic Environmental Impact Statement/Overseas Environmental Impact Statement (DPEIS) for marine seismic research. The American Petroleum Institute, Independent Association of Geophysical Contractors, National Ocean Industries Association, and US Oil & Gas Association also filed comments on the DPEIS (Industry Comments). CRE’s comments are inconsistent in several respects with the Industry Comments.
CRE is puzzled by these inconsistencies.
See, CRE’s complete discussion of the issue discussed below.