NRDC’s COMMENTS ON SEISMIC EFFECTS ON FISH ARE BASED ON OBSOLETE DATA, AND NRDC SHOULD DEFER TO NOAA/NMFS’ CONCLUSIONS ABOUT SEISMIC AND FISH

 The Council on Environmental Quality has reviewed and reported on the Bureau of Ocean Energy Management, Regulation and Enforcement’s compliance with NEPA. CEQ’s review focuses on BOEM’s NEPA practices and procedures that are relevant to Outer Continental Shelf oil and gas leasing.1
 
The Natural Resources Defense Council’s comments to CEQ’s (“NRDC’s Comments”) recommended, inter alia, that CEQ address the following substantive issues in its 30-day review…acoustic impacts on marine wildlife and fisheries.”2 NRDC further commented that

“Airgun surveys also have serious consequences for the health of fisheries, as they have been shown to dramatically depress catch rates of various commercial species (by 40- 80%) over large areas of ocean,8 leading fishermen in some parts of the world to seek industry compensation for their losses. The cumulative effects of seismic surveys combined with other noise-producing OCS activity, such as drilling, could both affect vital rates in populations of marine mammals and adversely affect certain fisheries. Given the significance of the potential impacts, uncertainties in the emerging science, and the difficulty of detecting demographic impacts in many marine species, MMS should be required to consider a worse-case scenario when evaluating the potential for adverse population-level effects.” 
 

 

Airgun surveys also have serious consequences for the health of fisheries, as they have been shown to dramatically depress catch rates of various commercial species (by 40- 80%) over large areas of ocean,8 leading fishermen in some parts of the world to seek industry compensation for their losses. The cumulative effects of seismic surveys combined with other noise-producing OCS activity, such as drilling, could both affect vital rates in populations of marine mammals and adversely affect certain fisheries. Given the significance of the potential impacts, uncertainties in the emerging science, and the difficulty of detecting demographic impacts in many marine species, MMS should be required to consider a worse-case scenario when evaluating the potential for adverse population-level effects.”   
 
See complete statement in the attachment hereto
 
NEPA NRDC Seismic
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