Reasons for BOEM’s industry-weighted policy decisions are becoming clear

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William Yancey Brown

William Yancey Brown

Last week investigative reporter David Hammer published a report on how the Department of the Interior’s Bureau of Safety and Environmental Enforcement (BSEE) appears to be sitting on their hands when it comes to performing the environmental enforcement aspect of their charge. It seems that while their budget has increased, allowing them to hire 77 petroleum engineers and geologists, they have only managed to fill two of the 12 positions open for environmental compliance staff.

Dialing back a few years the Department of the Interior’s Minerals Management Service was split into three agencies, BSEE, the Bureau of Ocean Energy Management (BOEM) and Office of Natural Resources Revenue (ONRR). This split was ushered in after the BP/Macondo disaster, but was in the making due to an embarrassing revelation that Minerals Management was way-too cozy with industry. It was the cocaine-dusted panty-parties that raised eyebrows, but when the oil-spill response plans for BP/Macondo revealed contingencies for walrus mitigation in the Gulf of Mexico it was clear the agency’s rubber-stamping of industry documents had exceeded the envelope of credulity.

The break-up of the agency into three independent functions was supposed to thwart abuse of MMS conflicting and overlapping missions of safety and environmental regulations (BSEE), resource development and leasing (BOEM), and revenue collection (ONRR). But David Hammer’s report indicates that since Michael Bromwich (the steward of the breakup) left his desk a few years back, the agency’s long-term staff has been returning to their old habits as handmaidens to industry. This trend was substantiated by former training center director Chris Barry, who was told by a supervisor that “as soon as Mr. Bromwich leaves, everything will go back to the way it was.”

This sheds light on the fact that despite preponderance of opposition to offshore development in the Arctic and the Atlantic, BOEM has been acting as if offshore oil and gas is a done deal. This includes attending “closed door meetings” with industry advancing extensive and redundant seismic surveys, and despite the overwhelming evidence to the contrary, the continued insistence by BOEM Chief Environmental Officer William Yancy Brown that these survey operations will have “no impacts on marine mammal populations.”

We got together with our colleagues at Oceana to address this “no impacts” peccadillo by lodging a Scientific Integrity Complaint against Brown with the Department of the Interior (DOI). We were chagrinned when our 156 page document citing “line, chapter, and verse” of the best available science (required for agency decisions) was summarily dismissed through a one-and-a-half page “closure letter” from DOI stating that they “found no merit to our charge.”

Not ones to shuffle back into our corner to mope we filed a request for reconsideration, cc’ing folks up the chain (DOI Secretary Sally Jewell and Solicitor Hilary Tompkins among others). Supposedly we should have heard from them by now, but given the aforementioned trend of “going back to the way it was” I get a sense that they may still be poking it with a stick to see if it’ll bite…

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15 comments for “Reasons for BOEM’s industry-weighted policy decisions are becoming clear

  1. Robert John
    October 4, 2015 at 12:13 pm

    Perhaps BOEM have ignored the 156 page document prepared by Oceana and Ocean Noise because it is a cherry-picked misrepresentation of FACTS and SCIENCE? I cannot believe that Ocean Noise would “get into bed” with Oceana when it is well known that they mislead a caring and giving public: http://thenorwoodresource.org.au/2014/04/26/how-can-oceana-justify-misleading-the public/ All this reminds me of the title of a book by Ian Plimer : “Telling Lies for God” in which he described the actions of creationists as operating “in the areas of fringe science picking over the carcass of science like hyenas”. This is surely what the likes of Oceana, Ocean Noise and the 75 so called “prominent” scientists (herded by NRDC) do : IGNORE most FACTS AND SCIENCE and pick a few extremely dubious research studies (eg De Soto et al on scallop larvae, Engas et al on fish catch: http://thenorwoodresource.org.au/2014/01/17/is-science-manipulated-by environmental-groups-and-some-researchers/). Perhaps BOEM’s response just reflects the fact that the likes of Oceana and Ocean Noise simply “Tell Lies for the Environment”??

    • mstocker
      October 4, 2015 at 4:53 pm

      Robert

      You’ll probably need to come up with more than one industry sponsored resource to build this case. I agree that the Oceana numbers on the amplitude of the seismic sources are noodles, but the Norwood source numbers don’t fare much better. I have made a point of avoiding numbers when communicating with the public because most people don’t understand the mathematical models. As far as “cherry picking,” and dissing the 75 scientists who chose to speak out about the impacts of seismic surveys: you might try to find 75 scientists equally qualified in this field to provide a rebuttal, but you would be hard pressed, because a good number of those 75 scientists cover the field of marine bio-acoustics. Any physical oceanographers who might want to chime in probably wouldn’t have the biological bona fides to dispute the evidence of behavioral impacts.
      I do find problems with the deSoto paper – much of which is pointed out in the critique. The problem in working with large wavelength signals is that you really can’t do this in a lab, and the field variables are hard to incorporate into a focused study. There are nonetheless many behavioral studies on marine mammals that pretty clearly indicate one disruption or another (migratory, foraging, vocalizations, social behavior).
      Regarding the quote by Geoffrey Harold Sherrington; He is functionally correct about what constitutes god science except for his condition about the “precautionary principle” serving as an excuse for “incomplete science.” There are many cases where our limited ability to understand or measure the interactions of large systems should not be an excuse to disrupt elements of the system “for the sake of science.” The precautionary principle just puts the onus on those proposing the disruption to know that it will not cause harm before hand rather than allowing them to blindly cause potential harm because “here is no evidence that harm will be caused.” Given the obvious deleterious impacts that our planetary habitat is suffering due to our lack of precaution, it would make sense to be more cautious as we expand our human enterprise out into the sea.
      As far as working with Oceana: They are a large organization and subject to the whims of their publicity and development departments. They provide us with a lot more coverage – which we need because we area small shop. But I have kept them honest in terms of our collaborative policy work – by not letting them use hyperbolic metaphors or quote questionable literature. We aim to be honest brokers, and up to now have focused pretty exclusively on presenting the science to the public in comprehensible terms so that the public can make informed decisions. We have been pulled into this policy discussion because BOEM has not been an honest broker. They are “lying by omission.” And if they chose to “cherry pick” – or in this case, chose to ambiguate good science, there is no amount of good science that will mitigate for the damage they are proposing at the behest of industry. As our mission is tied to preventing harm we have “taken the gloves off” in this instance.

      • Robert John
        October 5, 2015 at 1:55 am

        Michael,
        Thanks for posting my comment and for your considered and detailed response. I agree that it would be difficult to find 75 scientists willing to provide a rebuttal to the 75 who signed up for the NRDC letter, but would still suggest that would not be on the basis of the facts and science. I note that you are one of the signatories so, given the manner in which the letter is written (ie. more like a grab-bag of eNGO claims rather than a balanced scientific review), I wonder if you would care to be an “honest broker” and advise the public who really wrote it and whether there were any queries from these eminent scientists as to the content?
        After all, you say yourself that you “find problems with the de Soto paper” but yet you have signed up to the statement “In some species of invertebrates, such as scallops, airgun shots and other low-frequency noises have been shown to interfere with larval or embryonic development.” which was an obvious reference to the de Soto paper.
        It appears to me that, in the same way that creationists have to ignore many obvious scientific facts, the scientists who signed the NRDC letter to President Obama also ignored many scientific facts. For example, the ocean is noisy (icebergs calving/colliding, biological vocalisations, whales breaching, etc); no population impacts from seismic survey activity where whale populations have been closely monitored (eg NW Shelf of Australia); seismic survey mitigation measures such as soft start depend on behavioural responses; observations from seismic vessels demonstrate that the % of the population observed is not adversely affected, hence why would the unseen % of the population be adversely affected?; the physics of sound pressure level attenuation in water; etc, etc.
        The cynic in me leads me to conclude that scientists must have ulterior motives when they do not take into account ALL the scientific facts involved in a particular subject area.

        • mstocker
          October 6, 2015 at 12:23 am

          Robert,

          Briefly on who wrote the cautionary note: Christopher Clark, Ph.D., Scott Kraus, Ph.D.,Doug Nowacek, Ph.D.,Andrew J. Read, Ph.D, and Aaron Rice, Ph.D.. These folks are quite qualified to write this letter, and it is indeed based on many facts, and much science. What you may find disagreeable is that while the deSoto paper is not directly cited in the letter, there is a reference to it in terms of damage to marine invertebrates. The deSoto conditions were not an an analogy for what happens in actual field conditions, but there would be larval animals – invertebrates and otherwise that these surveys would likely draw through and damage. These are hard conditions to replicate in the lab, so we must, by inference assume that there are conditions that larval animals will be damaged or compromised by loud, low-frequency impulse noise.

          It has heretofore been the policy in science to not make these inferences because they do not meet the “repeat-ability” criteria for solid science. Unfortunately as we in the field are seeing all too much is that industry is justifying destructive practices because there is no “science” proving that it is destructive. Due to the heavy expense of doing replicable field studies we are seriously constrained. As those intimately familiar with the biology it is painful to see the system fabric torn apart and not have the “hard science” to stop it. This is why increasingly scientists are taking qualified stands on activities that are clearly compromising the field conditions. This is also why we are increasingly calling for the precautionary principle to be applied. It should be incumbent upon those proposing the damaging actions to prove that there is no damage, rather than dependent on those of us who are seeing the damage to prove without a doubt that the damage is occurring. If we do otherwise we will continue to see systems collapse before we even get a chance to know, let alone understand them.

          And while it is true that the ocean can be a noisy place, noise is not all of the same value. You can experience this by imagining the difference in your response if your house was built next to a noisy waterfall, or it was situated next to a freeway with equivalent noise level. Humans, and other animals are not just input devices that measure noise. Having big lumbering, continuous explosions in the sound horizon is not the same as having big, lumbering ocean waves hitting the beach.

          • Robert John
            October 6, 2015 at 7:27 am

            Michael,
            Thank you for your openness and honesty – especially with regards to who wrote the “cautionary note” for NRDC. You appear to be placing emphasis on the fact that all these people have Ph.D.’s. While they should be “quite qualified to write this letter” and you claim “it is indeed based on many facts, and much science”, I would still suggest that the content of the letter looks more like a grab-bag of eNGO claims and not a balanced scientific review of the issue. Surely a balanced review is the least one would expected from such a prominent mob?
            It is not simply the obvious reference (without naming it) to the de Soto paper that I find disagreeable. There are many examples, too many to quote and rebut in this comment, that I find extremely misleading and, in fact, pseudo-scientific.
            Let’s start with the first paragraph:
            “This activity represents a significant threat to marine life throughout the region (
            U.S. mid-Atlantic and south Atlantic coasts).”
            Why is this area so different from the Gulf of Mexico and other ocean margins such as the South American Atlantic coast, African Atlantic Coast, European Atlantic Coast or the Australian Indian Ocean coast, where seismic surveys using compressed air have proceeded for over 4 decades with no significant impacts to marine life? This claim is not supported by the facts and science. In fact, the Group IV humpback population growth on the NW Shelf of Australia since the cessation of whaling in the 60’s demonstrates quite robustly that seismic surveys and petroleum development activities have NOT been a “significant threat” to marine life.

            Let’s look at the second paragraph: “with sound almost as powerful as that produced by underwater chemical explosives.”
            This is very misleading scientifically and I can only assume it is deliberate! What does “almost” mean? Surely, it cannot mean as much as twice as powerful (ie 6dB difference)? As you have said you don’t like dB numbers it is probably best to keep away from dB levels in this comment. However, what about pressure – due to the fact that the key attribute of a sound pulse’s likelihood of causing damage is the pressure or rate of change in pressure? Seismic arrays operate at 2000psi whereas chemical explosives generate pressures of 3,000,000psi – that’s a very significant difference in pressure and definitely not “almost as powerful”.
            In that same second paragraph, 75 prominent scientists, with Ph.D.’s, have demonstrated that they have minimal understanding of the multi-client or speculative survey model in which seismic contractors acquire seismic data in an area and sell it to multiple clients. While there may be multiple applications to conduct surveys over the area, there is NO way that all will actually be acquired – market dynamics will sort out the few that are eventually acquired and there is NO way there will be “multiple duplicative efforts in the same areas”. I note that one of the writers of the letter (Doug Nowacek) is still confused about this model.
            Need I go on? I could rebut many more statements about the “NRDC 75 prominent scientists letter” but this is not the place to do it.
            Let’s return to your statement at the end of your second paragraph: “If we do otherwise we will continue to see systems collapse before we even get a chance to know, let alone understand them.” Surely you are not saying that systems have collapsed due to seismic surveys and petroleum development? If they had, there would surely be ample evidence of this after over 40 years of offshore exploration and development?
            Thanks again for your response – I am pleased we are having this discussion – and hope that at least a few of your 74 colleagues are following!?

          • mstocker
            October 7, 2015 at 1:16 am

            Thanks to you as well Robert for your patience and persistence in at least tossing this back and forth. For the record: I am not emphasizing the “Ph.D” as a necessary qualification. It does indicate that someone has the perseverance and drive to work through an academic program. By inference it indicates that these people have spent a long time in close proximity to their field of inquiry and are thus likely to be much more conversant in the development and vocabulary of their particular study. Folks from this group are generally more focused on marine biology, which is not an exact science. Biologists have commonly been at odds with folks who are conversant in physics and engineering – which tend to be more exact. This disparity in disciplines has been a source of much of the grief in this larger field of bio-physics, and there are artifacts of this in our conversation.

            Having feet in both worlds I tend to argue the perimeters of each, and for quite a long time I was of the mind that seismic surveys were of negligible consequence – at least from an energy exposure and physiological impact standpoint. And under this rubric I did take issue with the ambiguous phrase in the letter comparing air-gun impulses with chemical explosives. I have been arguing for over a decade that sound qualities – particularly rise time and signal kurtosis are far more important expressions of impact than amplitude. It has only been in the last few years that these nuances are making the peer-reviewed papers.

            I believe that the nuances are what troubles the physical oceanographers. And this is evident in your observation that there are many areas in the ocean where seismic surveys are taking place where there are also marine mammals that seem to be coping just fine. Unfortunately from a biological standpoint we have absolutely no baselines to use as a comparison. The concern for the impacts and consequent studies have occurred well after the fact – when there are also far too many other systematic stressors to effectively single out just one. So in this case we need to rely on the instances where behavioral impacts from survey exposures are clearly observed. Increasingly these papers are being published – where there are behavioral disruptions clearly associated with exposure to seismic surveys. I will send you a simple handful to your e-mail address.

            What is not expressed on the letter, but what concerns me the most is that once the airguns go into the water the entire habitat begins a transformative journey toward becoming an industrial soundscape. Ongoing extraction-monitoring surveys, mechanical noise from seafloor processing, underwater acoustical communication networks, increase in large vessel traffic, etc. There is ample evidence in terrestrial epidemiology equating industrial and urban noise to stress and consequent diseases associated with metabolic stress. There is absolutely no reason to discount these impacts in marine life.

            I don’t know how many of the 75 are aware of the Offshore E&P environment. This is another area where I have been waving flags because I am much more concerned about the long-term compromise of the habitat from the many other E&P associated noise sources. Unfortunately the term “seismic airgun blasting” expresses alarm more effectively than “multi-nodal acoustical communication networks.” But these are inextricably tied, and the surveys are the gateway for a lot more disruption. It is by way of this that I have signed onto the letter, understanding that the tools of public engagement and policy development are blunt and lugubrious – but necessary if we are mitigate our impacts on the ocean.

          • Robert John
            October 7, 2015 at 10:28 am

            Michael,
            Thanks for continuing the discussion.
            Excuse me for thinking you were emphasising the Ph.D. credentials of the core group who wrote the draft cautionary note to President Obama. It’s just that you had ‘Ph.D.’ after every name – hence my confusion. In my experience, Ph.D.’s end up knowing a lot about a very narrow subject and, quite frankly, should not be regarded as experts in subject areas they obviously know very little about.
            I’m pleased that you’ve identified one of the issues, that: “Folks from this group are generally more focused on marine biology, which is not an exact science.”
            I’m also pleased that you say that you have “feet in both worlds”.
            However, I must say I am surprised by your statement “Unfortunately from a biological standpoint we have absolutely no baselines to use as a comparison.” This is exactly what I was referring to regarding the humpback population on the NW Shelf of Australia – see item 3 in the following link: http://thenorwoodresource.org.au/2014/07/30/the-right-to-protest-or-lobby-should-not-be-abused/
            If the population growth of the humpback whale in this area is not a classical case of a baseline study, I am at a loss to understand what you mean. I would suggest that, if there were similar studies of different cetacean populations in areas where seismic activity has occurred over more than 4 decades (since the cessation of whaling), the results would be similar (unless the population decline was obviously due to, for example, by-catch, as in the case of the Maui’s dolphin in NZ).
            In fact, I’m extremely surprised that, given the knowledge of humpback populations and the preliminary results of the BRAHSS (Behavioural Response of Australian Humpback whales to Seismic Surveys) study, which is still not published but has been reported at a number of conferences, that a humpback whale researcher (Olaf Meynecke, Ph.D.) would add his signature to such a letter.
            Perhaps it is the same reason that many of the 75 prominent scientists “jumped on the bandwagon”, especially given my understanding that quite a number of signatories did not agree (as you have mentioned yourself) with ALL the claims in the letter.
            Thank you also for sending me, to my email address, the summary of papers that show “behavioral disruptions clearly associated with exposure to seismic surveys.” I am very familiar with most of those papers and I will look forward to responding to you privately by email regarding their validity in this issue. However, given that one of the papers was the Rollond et al study and Rollond plus some of her co-authors (Parks, Nowacek, and Kraus) signed the NRDC letter to President Obama, I cannot resist commenting on the quality and implication of that paper. Firstly, it is not about exposure to seismic surveys as you have implied in your comment (Rollond’s paper was about ship noise); secondly, a very respected acoustic researcher I know has described this paper as “poor science lacking in rigor”; and thirdly (most important of all), I am at a loss to understand how these prominent authors could realistically claim that the reduced stress detected was due to the removal of ship noise and not the removal of the risk of collision especially in an area reknowned for deaths due to collision.
            Thanks again for continuing this discussion.

          • mstocker
            October 8, 2015 at 12:02 am

            Robert,
            While these folks may not be specialized in geo-physics, many are experts in biology – which in fact is what this issue is about: How geo-seismic surveys are impacting marine life. Regarding baselines; I mean that I am unaware of any clear population growth and recruitment studies on whale populations that are not and have not been under a myriad of stresses that would likely impact their reproductive success. One cannot just assume that after the end of industrialized whaling that populations began increasing at a rate equivalent to their success rates before industrial whaling and seismic surveys. That the population is increasing while subjected to survey noise is proof that life is tenacious, not proof that the noise has no impact. Whales continued to procreate doing whaling, just not fast enough to overcome their slaughter. As seismic surveys do not kill these whales it stands to reason that their populations would increase. But what the rate? What about longevity? What about metabolic function and overall health? We have no idea. And now that there are so many other stressors – bycatch, entanglement, ship strikes, bio-accumulation of anthropogenic toxins, food source competition, etc. – we will never have any meaningful baselines on non-molested population health.

            What these biologists are attesting to is that seismic surveys have clear and deleterious impacts on marine mammals. This is why it does not surprise me that Olaf Meynecke signed on – I have heard some of the BRAHSS presentations, and before publishing the report apparently Olaf felt that the evidence supported his signing on. It doesn’t surprise me that Doug Cato did not, but he is the PI and has the responsibility to see the report run through peer review prior to advancing comments one way or the other.

            As for the Rolland, Parks et.al. I have not heard the piece disputed. I’d like to hear the disputes, but it was a study of opportunity done in retrospect and (fortunately) a rare opportunity so the methodology was a matter of data mining, not a set-up study. What was clearly demonstrated was that N. Atlantic Right Whale stress levels was correlated to shipping activity. Segregating shipping noise from shipping motion doesn’t hold much water – as the animals are aware of the ships on account of hearing the noise, not because they see the ships. As in humans, dangerous noises alert us to dangerous activities. The noise and the activity are inseparable. Similar studies have been done with birds during the same period. I recall myself during the same event when there were no airplanes flying how calm the horizon felt/sounded after a day or so. Yes it is shipping noise and not airgun noise, but it is introduced, loud, mechanical noise. Besides, the surveys also require ships. Although if you figure out how to trawl airguns without a ship let me know and I’ll quit my job and help you sell the technology!

            In closing I will fall back on the “sentimental” aspect of this argument that is really at the root of public conservationist’s concerns: How would you like it if some giant vessel started relentlessly dragging these surveys through your neighborhood without your permission or consent?

          • Robert John
            October 8, 2015 at 9:55 am

            Michael,
            Thanks for staying with this, given that we are trying to have a discussion on the basis of the facts and science. However, I do realise that, given your area of interest, you probably prefer to discuss this issue on the basis of opinion, anthropomorphism and, in your words, sentimentality.
            I totally agree that the nub of this issue is “How geo-seismic surveys are impacting marine life”.
            However, don’t you find it surprising that, after over 4 decades of seismic surveys using compressed air, there are no verified adverse impacts on cetacean populations as a result of seismic survey sound? And that is despite very close monitoring, much closer than the monitoring of the shipping, fishing and, dare I say, defence, industries?
            Yes, there are behavioural responses, which we actually want as it is regarded as the main mitigation measure.
            However, many researchers in this area are certainly “drawing long bows” and relying on opinions as opposed to facts, plus a remarkable leap of faith, when they claim that seismic surveys “represent(s) a significant threat to marine life” when the papers mainly claim they “may”, “could”, “can” or “potentially” represent significant threats to marine life.
            My understanding of cetacean population growth baselines, especially humpbacks, do indicate we have the information to arrive at conclusions that there are NO adverse impacts at population level from seismic surveys or petroleum development. The Group IV and the Group V humpback populations have grown very similarly at a rate very close to biological maximum (11-12% pa) and yet there is very little seismic survey or petroleum development in the Group V migration and wintering areas. What does this suggest? All I can gather from these facts are that seismic surveys have had NO adverse impacts on these populations (especially as the other stressors you mention would be similar throughout the two areas).
            I am very pleased that you do accept there are many “other stressors – bycatch, entanglement, ship strikes, bio-accumulation of anthropogenic toxins, food source competition, etc.” that threaten cetacean population viability. As you are no doubt aware, some of these, such as by-catch, have been roughly quantified on a world-wide basis (eg 330,000 cetaceans pa; 650,000 if seals/sea-lions are included). Although ship strikes are frequent (especially by fast moving ships like cruise liners, etc) I am not aware of any effort to quantify these impacts.
            I am left to ponder why a group of 75 prominent scientists choose to “point the finger” at noise when there are so many stressors known to have major impact (ie DEATH!) on individuals and hence cetacean populations (and I would not be surprised if at least one of these prominent scientists has been on a cruise!).
            Finally, I am intrigued by your comment “It doesn’t surprise me that Doug Cato did not (sign the letter)” because it sounds like he was invited to and either declined or abstained.
            In the interests of being an “honest broker” perhaps the following details should be published about the background to that letter:
            How many scientists were invited to add their name to it?
            How many declined?
            How many did not respond (ie. effectively abstained)?
            I am convinced that, if one considers ALL the facts and science, there is more to the NRDC letter than a simple concern for marine life.

          • mstocker
            October 9, 2015 at 12:13 am

            Robert,

            I take umbrage at your opening statement, as it seems to represent more about your opinion than about the scientifically substantiated statements I have been using to build my argument up to the closing comment in my last response. You need to also understand that while “science” is a helpful methodology to establish repeatable evidence, the results can only provide a rough approximation of the actual world in which we reside. This is because science depends heavily on isolating variables so that they can either be excised from the field of observation, or accounted for in the models. But the real world in which we reside – including the limited field of our conversation includes an unaccountable amount of variables, so we can either ignore this in our discussion, or admit that the science provides a useful but limited lens through which we can come to some agreements.

            This is clearly represented in your statement that “there are no verified adverse impacts on cetacean populations as a result of seismic survey sound.” This statement first offered by in the press by BOEM Chief Environmental Officer William Yancy Brown is true – because there have been no systemic population impact studies of seismic surveys on marine mammal populations. But it is wrong because there is ample evidence that seismic surveys disrupt marine mammal behaviors. This is a common case where the lens of the inquiry is focused for convenience (population level impacts) and not for understanding (behavioral impacts).

            That I use sentience as a lens does not “anthropomorphize” the perspective. It is gross “scientific fundamentalism” that maintains these animals are merely input devices without sentience. And without a clear way of “asking them if they are bothered by the disruption” we must make some logical assumptions that are evident by way of avoidance behavior and elevated stress hormones under similar exposures. We are led to pursue these assumptions by asking empathic questions: “how would this stimulus impact me?” If we see responses that mirror our own responses we can make an informed assumption that there is some probable correlation. This may not be physics, but it is a tool used in behavioral science.

            This leads to your comment that implies avoidance response being an acceptable mitigation measure. I suggest that if avoidance behavior was used in residential noise regulations we would be living in much more hostile neighborhoods. Not to anthropomorphize, but by creating noise fields that chase animals out of their natural habitats, we are effectively colonizing habitat that they would otherwise use for feeding, breeding, sleeping, and socializing. This disruption would have measurable population impacts should we chose to explore that metric.

            There is another aspect of this in play here – which while it did not show up on the letter, it did feature prominently in most of the critiques of the Atlantic G&G PEIS’s that I read, which is that seismic surveys are a precursor to fossil fuel leases and extraction. And while it was not in the purview of the PEIS, it is clearly understood that fossil fuel is pushing our planetary life support system into thermal runaway. It is suicidal to continue to extract and burn fossil fuel, and madness to continue to throw gargantuan resources toward this end when we need to throw those resources at halting energy policies that continue to increase greenhouse gasses into our environment.

            This is one of the reasons “we” are targeting seismic surveys – because they are a gateway to something we must stop. Of course I would like to “stop” ghost nets, and “stop” ship strikes. But by stopping seismic surveys we not only stop the short-term damage to animals and habitat, we also slow down the continued development of fossil fuels. This is part of the larger system (and our larger strategy) which really has little to do with the comparative impacts of whether seismic surveys or plastic debris are more harmful to marine life.

            In terms of who did, and who declined to sign on to the letter: We asked colleagues who we thought would sign. I didn’t ask Doug Cato, but perhaps NRDC did. I don’t know, but this metric would not be really that meaningful as we ended up getting a significant population of qualified scientists to sign on and did not get many declines.

            At this point I believe the water has been run on this discussion. I’m glad it has been largely civil, but I suspect that aside from getting a chance to air our perspectives we have not much changed each others opinions about the impacts of seismic surveys on marine habitat. I’ll likely point to this exchange for others as I believe it sheds light on common arguments found on two common sides of this discussion.

          • Robert John
            October 9, 2015 at 10:21 am

            Michael,
            It is disappointing that you’ve “taken umbrage” as a result of my opening statement in my last comment and that you would like to stop this discussion because it has run its course. However, I’m not surprised, given you believe you’ve used “scientifically substantiated statements” to build your argument yet still appear to be arguing on the basis of opinion, anthropomorphism and sentimentality.
            I also find it remarkable that you have admitted that “your” ulterior motive is attacking the “continued development of fossil fuels. This is part of the larger system (and our larger strategy)”. It implies that you have no problems with ignoring most of the facts and science in this subject area for the ‘greater good’ ie. stopping the continued development of fossil fuels.
            I totally agree that we should move towards a more sustainable energy mix but this should be based on a balanced, open and transparent debate.
            Finally, while you may have an opinion on this issue and have accused me of also having an opinion, I can assure you that I my position is based on all the facts and science, not just selected portions. I would be happy to change my position if all the facts and science supported it.

          • mstocker
            October 9, 2015 at 5:10 pm

            I figured with your dismissive comment that I “probably prefer to discuss this issue on the basis of opinion, anthropomorphism and, in your words, sentimentality.” That we were done with anything productive. We have both offered arguments substantiating our positions, I have been open and candid with you about our systematic reasoning and larger objectives, and you have presented a “lock-box” argument that does not include the scientific and empirical evidence that I have presented. With your siloed argument on the one side, and my systematic argument on the other it is apparent that we won’t settle our differences in opinion through the opacity of our different perspectives. Time will only tell which of us is “more correct.” Unfortunately from where I sit and the way that “market forces” dominate our national and international priorities the tale does not look encouraging.

          • Robert John
            October 9, 2015 at 9:53 pm

            Michael,
            I agree with your comment “Time will only tell which of us is “more correct.”” and am left to ponder why you still ignore the lack of evidence of “significant impact”, including evidence to the contrary, during last 40 years of seismic surveying, in your “systematic reasoning”.

          • mstocker
            October 10, 2015 at 4:22 am

            Robert

            I believe I have clearly expressed why I feel that seismic surveys are disruptive, and I believe that the many scientific citations I provided to you substantiate these disruptions. Just because animals are capable of procreating in a field of human-generated noise does not mean that the noise is harmless. I am still of a reductive mind that will agree that the actual physiological impacts from seismic surveys are no greater than the physiological impacts of the “noise” of ocean waves pounding on the seashore. And as you know there is much greater energy imparted into the system by way of the pounding waves, and certainly at present these noises are more common in the ocean – at least in coastal waters, than the pulses of surveys.

            But as I spend more time in the water with marine vertebrates I understand that they are much more complex than the “scientific” models suggest. They have personalities – humor, compassion, delight. And this is not just cetaceans, or pinnipeds, or mustelids; I also include fish and sharks. I am not “anthropomorphizing” here, any scuba diver will attest to this. Animal “play” is not an “instinct,” it is simply play. The same holds true for grief, anger, fear, and in some species “conjecture.” In this context it is unconscionable to blithely subject these animals to our acoustical excrement just so we can continue to drive our civilization into the technological smog we feel is “acceptable” to us, and thus acceptable these other creatures.

            We humans have, and continue to choose to live in the acoustical haze of our own making. We know that human miscarriage rates in the flight paths of airports are significantly higher than in adjacent areas, but we continue to build houses in the flight-paths of airports. We are all familiar with the cancers and eczemas, and digestive problems and anxieties that are associated with stress. There is no question that living in an urban environment contributes to this stress. But even in the incessantly elevating pressure of our civilization we continue to rapaciously procreate. I wish this were not the case, but nature is like that. Procreation is the engine of nature. Reproductive success in the short term will lead to catastrophic die-off in the longer term – providing fertile food for the continuous procreation machine in the even longer term. We humans, in full knowledge of this axiom continue to push the envelope of our own demise.

            But it is one thing for us humans to continue our trajectory with this knowledge. It is quite another to insist all other creatures (and humans) suffer at the expanse of our “success.”

            We both know where this is heading. In 10, 20, or 30 years – or perhaps tomorrow, this will mean nothing to us. But early on in my life I decided that my guiding principle would be to advance the highest quality of life for the most beings on our planet. This is why I do what I do.

            This simple yard stick keeps me talking.

            Respectfully

            Michael

          • Robert John
            October 11, 2015 at 9:39 am

            Michael,
            Thanks for your openness and honesty.
            While we are obviously not on the same wavelength regarding facts and science it appears we are very much of a similar mind on 2 key issues of our time:
            1. Human beings continue “to rapaciously procreate.” (I consider this to be society’s biggest problem, yet discussion of this topic is generally “taboo”); and
            2. We both have guiding principles that “advance the highest quality of life for the most beings on our planet.”
            However, regarding item 2, I tend to focus on animal populations that are clearly being decimated by human impacts (eg Australian wildlife), whereas you appear to focus on marine populations that “may”, “could”, “potentially” be decimated by noise in the ocean.

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