Jolie Harrison, Chief, Permits and Conservation Division,
Office of Protected Resources,
National Marine Fisheries Service.
1315 East-West Highway, Silver Spring, MD 20910
We the undersigned oppose seismic airgun blasting in the Atlantic Ocean. We ask you consider the following reasons as related to the Marine Mammal Protection Act and other rationale to deny the 5 permits granted to survey companies and stop any further activities related to seismic activity in the Atlantic Ocean.
The Marine Mammal Protection Act (MMPA) requires that the National Marine Fisheries Service (NMFS) prove that only “small numbers” of individuals from a stock, population, or species of marine mammal are impacted or harmed by offshore activities, like seismic airgun blasting. Given that five seismic airgun surveys are being considered in overlapping areas, there is no way for NMFS to meet this requirement—in fact, the government estimates that thousands of marine mammals could be impacted by these activities. The cumulative impact of conducting 5 seismic airgun surveys overlapping in time and space on marine mammals and marine wildlife in the areas proposed should be considered by NMFS when considering the impact of the proposed Atlantic seismic airgun surveys.
Additionally, under the MMPA, NMFS must prove that the proposed seismic airgun activity will have no more than a “negligible impact” on stocks or populations. Again, this seems nearly impossible with five surveys being permitted, especially for North Atlantic right whales. This population of whales is so endangered, that losing even a few individuals could threaten the survival of the entire species.
Finally, the suggested mitigation measures will be inadequate because there is no baseline data for most of the species that would be impacted, so NMFS and the public will have no way to definitively determine if marine mammal populations are affected by seismic airgun blasting.
Please accept the undersigned signatures as individual comments regarding the above statements.