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Where We Stand on Seismic Regulation
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.
Summary
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.
The Southall Criteria are infeasible with regard to regulation of seismic behavioral effects, and they should not be used to regulate those effects.
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