CRE Comments on BOEMRE’s Scoping for its Multisale Environmental Impact Statements

CRE  comments  focused on the following  topics:

 Models should be used only after they have been verified 

Proprietary models and all other acoustic models should also comply with BOEMRE’s Information Quality Act Guidelines, which require that 

 “In situations where public access to data and methods will not occur due to other compelling interests, we will apply checks to analytical results and document what checks were undertaken. Our guidelines will, however, provide the specific data sources used, and the specific quantitative methods and assumptions we employed unless such information is deemed proprietary. We will define the type of checks, and the level of detail for documentation, given the nature and complexity of the issues.”

 There is no evidence that seismic operations have caused a decline in Sperm Whales, Killer Whales or Byrde’s  Whales

 NMFS’s surveys indicate that the Mississippi River Delta area has a particularly high number of cetaceans, and “by 1989, it was certain that many types of cetaceans lived in the deepwaters of the Gulf.”  Id. These whale species and other marine mammals in the GOM have co-existed with oil and gas industry infrastructure and activities for decades.  There is no evidence that seismic operations have caused a decline in their numbers. The best available data indicate that sperm whale numbers increased in the GOM during the period 1996 to 2004.

 There is  no reason to believe that seismic operation in the GOM have caused whale strandings

  NMFS has explained  that

 “To date, there is no evidence that serious injury, death, or stranding by marine mammals can occur from exposure to airgun pulses, even in the case of large airgun arrays”.

Existing Mitigation Measures Are Sufficiently Protective of  Marine Life

 More specifically, current safety measures protect marine life. Geophysical contractors’ established use of marine mammal observers, safety exclusion zones, and soft-starts to ensure that seismic surveys do not harm whales 

Existing Mitigation Measures Are Sufficiently Protective of  Marine Life

 More specifically, current safety measures protect marine life. Geophysical contractors’ established use of marine mammal observers, safety exclusion zones, and soft-starts to ensure that seismic surveys do not harm whales.

See CRE comments below.