PGS “Ramform Titan” Seismic Survey Vessel
After eleven years of effectively blocking the geophysical (seismic) survey off the Mid-Atlantic Outer Continental Shelf (OCS) the shoe has finally dropped. Last Friday morning the National Oceanographic and Atmospheric Administration (NOAA) issued “Incidental Harassment Authorizations” (IHAs) for five seismic survey projects to map Mid and South-Atlantic hydrocarbon deposits. This was, of course, a week after the United States Global Change Research Program released their report on the dire consequences we face with the climate catastrophe.
The request for surveys originally came up in 2007, just before a long-standing offshore drilling moratorium was dropped. It was thought that the public should know what assets we had on the Atlantic OCS. As the moratorium was still in place, and for pretty much anyone who understood the global climate situation, the dominant question was “if we’re not going to drill for oil, why go looking for it?”
But the Department of the Interior (DOI) knew something we didn’t at the time – that the moratorium was going to be lifted. Once it was lifted, the survey data was worth something. This prompted a raft of geophysical companies to jump into the opportunity of “maximizing the market value” (i.e. privatizing) of the survey information they planned to acquire on our public OCS – ostensibly to sell to the oil companies interested in leasing offshore tracks for fossil fuel extraction.
These surveys are fairly disruptive. Comprised of towing arrays of seismic airguns and hydrophone streamers in large track patterns behind a survey vessel, the airguns discharge every 10 to 15 seconds, sending out high-energy pulses into the sea bed (and out into the surrounding ocean). The returned signals can be deciphered to reveal geological details down to thousands of feet below the sea floor. But these signals also propagate out into the ocean and can be heard hundreds-to-thousands of miles away from the source – potentially damaging animals in the near field, and disrupting any animal within hearing distance.
Unfortunately, while there is ample evidence of this disruption on marine mammals, fish, and even marine invertebrates, the current regulatory thresholds offer only an approximation of caution based solely on marine mammal hearing thresholds. And the regulation is solely through the lens of exposure impacts on individual animals – without consideration of population-level impacts, which are actually more crucial, as they point to long-term survival of a species. Regrettably, population impacts were down-played in NOAA’s biological opinion on the permits.
One of the outstanding practical concerns in terms of biological impacts is; why there is a need to have five different companies survey the same area at the same time (aside from the “maximization of market value” mentioned above). In 2015 I asked the NOAA fisheries chief Eileen Sobeck about modifying the exposure metrics to reflect impacts for concurrent and duplicative surveys. She said that she didn’t want to open that up (so much for the “best available science…”)
There remains a number of unanswered questions. I will be going through the IHAs and responses to the public comments, but one of the responses to a question at a NOAA Press Conference on Friday as to why the public is so interested in this issue, Donna Weiting, the head of NOAA Office of Protected Resources answered “we have no way of knowing what is in the public’s mind about this issue.” One would think after synthesizing 120,000 public comments on it, they might have a clue…
We will be synthesizing the documents released with the permits; the Biological Opinion, the “Findings of No Significant Impacts” (FONSI) and the public comments, and find out if and how the public comments were taken into consideration in the release of the Authorizations.
The account is not settled yet. It appears that NOAA has not adhered to procedures, ignored public input, based their decisions on incomplete, faulty, or obsolete data, etc. While litigation is not our remit, I hear the sharpening of the blades in the offices of our legal colleagues.
Meanwhile, stay tuned. Shortly I will be sending out a list of actions you can take to keep this matter on the front burner, to be served up hot on the desks of our Representatives in Washington.