Protect Marine Mammals from Offshore Drilling Activities
Action needed by 28, 2013
The Arctic sees lots of visitors throughout the year, from migrating birds to migrating whales, millions of animals pass through Alaska each year. But there are some that hold steady, including the bowhead whale. Bowhead whales live their whole lives in the Arctic, never migrating south, which leaves them vulnerable to possible future oil spills.
When we look at the future of the Arctic, corporations are trying to make it unrecognizable. Today, we have the chance to make sure marine mammals cannot be impacted by possible oil and gas activities.
Attend a public hearing this week and urge the National Marine Fisheries Service to adopt a plan that keeps bowhead whales and other marine mammals safe.
Comment on the Supplemental Draft EIS
The public comment period ends on Tuesday, May 28, 2013. Submit comments by:
Attending a public hearing:
Chief, Permits and Conservation Division,
1315 East-West Highway, Room 13705,
Silver Spring, MD 20910
Electronic Submission: Submit all electronic public comments via the Federal e-Rulemaking Portal (www.regulations.gov). To submit comments via the e-Rulemaking Portal, enter NOAA-NMFS-2013-0054 in the keyword search. Locate the document you wish to comment on from the resulting list and click on the "Comment Now" icon on the right of that line.
Oil and Gas Activities Could Have Dangerous Effects on Marine Mammals in the Arctic Ocean
Talking Points for the Public Hearings on the National Marine Fisheries Service’s Analysis of Oil and Gas Exploration in the Arctic Ocean
The National Marine Fisheries Service (“NMFS”) has recognized there could be long-term, harmful impacts to marine mammals from expanding oil and gas activity in the Arctic. As a result, NMFS has been working with other government agencies to analyze the combined effects of multiple oil and gas activities in the Arctic Ocean. Over the last few years, NMFS has prepared a number of draft documents which present an analysis of how various levels of oil and gas activities will affect marine mammals, including both seismic surveys and exploratory drilling.
In its most recent draft document (the Supplemental Draft Environmental Impact Statement), NMFS is considering the effects of three different levels of exploration activity and has increased the highest level of activity to include four additional exploratory drilling programs. All of the alternatives in this new statement (except no action) propose the approval of multiple seismic surveys in the Beaufort and in the Chukchi Sea each year, one on-ice seismic survey in the Beaufort Sea, and at least one exploratory drilling program in the Beaufort and Chukchi Sea per year. The highest level of activity includes up to eight total exploratory drilling programs, up to twelve seismic surveys, and up to five other types of surveys. NMFS is also analyzing whether to implement time-area closures in the Arctic, among other relief measures, to help lessen the damaging impacts of oil and gas activity.
NMFS is seeking public comments on this document. It is critical that all interested parties provide input, because this document will guide future government decisions about oil and gas exploration in the Arctic Ocean for at least the next five years. NMFS will also rely on this document in order to review Incidental Take Applications that allow harassment of marine mammals from seismic surveys and exploratory drilling in the future.
ØNMFS must examine whether the activity levels it analyzes meet the law’s requirements: The Marine Mammal Protection Act is a very protective statute—it prohibits activities that harm marine mammals unless NMFS determines that the activity will have only a negligible impact on the population and will harass only a small number of animals. NMFS should describe in the Draft Impact Statement whether the activities it analyzes will have only negligible impacts and harass only a small number of animals. It does not do so. If it did, we think NMFS would have to conclude that the activities, even at the lowest level it analyzes, do not meet these requirements.
NMFS’s document reveals that oil and gas exploration activities could have far-reaching consequences for marine mammals in the Arctic Ocean. If the highest level of activity occurs, acoustic noise from drilling and surveying operations could harass 80% of the endangered bowhead whale population, about 40% of the threatened ringed seal population, and about 25% of the Chukchi Sea beluga whale population. The Draft Impact Statement also reveals that the highest level of activity could have major impacts on bowhead whales. Even at the lowest level of activity analyzed in the document, 30% of the bowhead population, about 30% of the ringed seal population, and about 13% of the Chukchi Sea beluga whale population could be disturbed.
Considering these potentially serious impacts under all the action alternatives analyzed, NMFS should conclude that any of the action alternatives would meet the law’s requirements. This is especially true in light of the rapid shifts in the Arctic Ocean due to climate change, the importance of marine mammals to the subsistence way of life, and major gaps in basic information about the biology of the Arctic Ocean.
ØNMFS should analyze additional time and area protections:
oNMFS has identified a number of areas that are important to species and is analyzing alternatives that would protect these areas by closing them to exploration activities during certain times of the year. There is a chart attached to this document which describes all the time-area closures NMFS is considering in this Draft Impact Statement. Please provide input about whether there are additional areas that deserve consideration or additional time limits that should be in place.
oFor example, NMFS should include Camden Bay as an area to be protected. In previous draft statements, NMFS identified Camden Bay as important habitat for bowhead whales, because it is a potential feeding area and is important for subsistence hunts. In the most recent Draft Impact Statement, NMFS has decided to exclude Camden Bay from consideration as an area to protect. It states that it does so because bowhead whales have not been observed feeding there in the last few years. But this recent data is not enough to support a conclusion that the area is no longer important for bowhead whales, particularly because NMFS is supposed to take a protective and cautionary approach. NMFS should include Camden Bay as an area in need of special protection.
ØNMFS should update the way it measures impacts: In this Draft Impact Statement, NMFS acknowledges that it is in the process of changing the way it measures how sound can harm marine mammals. NMFS states that the new criteria will likely increase the estimate of bowhead whale numbers that are disturbed by exploration activity. However, NMFS uses the old, soon-to-be outdated criteria for measuring impacts, and this old method may understate potential harm to marine mammals. NMFS should use the new and more protective way to measure harm from sound.
ØNMFS should consider alternatives that limit the level of exploration activities that could occur in the Arctic Ocean: NMFS does not consider any alternatives that would put an overall limit on the number of activities that could occur in the Arctic Ocean or cap the overall level of sound that could be introduced into the Ocean. Because multiple sources of noise can have serious effects on marine mammals, NMFS should consider such limits. For example, it should consider limiting the number of noise sources in the Arctic Ocean in a given year. It should consider alternatives that ensure that activities do not simultaneously occur close to each other. It should consider alternatives that restrict duplicative seismic surveys that needlessly subject marine mammals to harassment when areas already have been surveyed in the past.
© copyright Sierra Club 1892-2014