NRDC Comments on Seismic Exploration


 In endangered baleen whales, they [seismic airguns]  have been shown to both disrupt and mask communication – substantially compromising the animals’ ability to forage, find mates, and engage in other vital behavior – on population-level scales.

 Given the significance of the potential impacts, uncertainties in the emerging science, and the difficulty of detecting demographic impacts in many marine species, MMS should be required to consider a worse-case scenario when evaluating the potential for adverse population-level effects. 



The Council on Environmental Quality is reviewing the Bureau of Ocean Energy Management, Regulation and Enforcement’s (“BOE”NEPA practices and procedures that are relevant to Outer Continental Shelf oil and gas leasing. The Natural Resources Defense Council submitted comments on CEQ’s review (“NRDC’s Comments”).

NRDC’s Comments argue, inter alia, that the oil and gas industry’s offshore use of seismic airguns poses significant risks to marine mammals and fisheries.  NRDC’s Comments further argue that these risks must be addressed through changes in NEPA procedures. NRDC’s requested changes include rules and legislation that require BOE to defer to NOAA on seismic issues.  The National Marine Fisheries Service is the NOAA entity most directly involved with seismic issues.

NOAA/NMFS recently rejected NRDC’s arguments against seismic in another proceeding.  This other proceeding is the Incidental Harassment Authorization (“IHA”) that NOAA/NMFS issued to Statoil under the Marine Mammal Protection Act (“MMPA”).  NRDC and others were critical of this seismic IHA for Alaskan waters, and argued against it on many grounds, including potential harm to bowhead whales.  NOAA/NMFS rejected these arguments and concluded that, as currently regulated, seismic doesn’t pose much of a risk to anything at all.

See the attachment below for the complete article.




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