Protect Whales and Dolphins From Sound Bombs

Sound is a fundamental element of the marine environment. Whales, fish and other wildlife depend on it for breeding, feeding, navigating and avoiding predators -- in short, for survival. Now a plan to open the mid- and south Atlantic Ocean to seismic exploration could drastically transform the marine environment along most of the East Coast.

Seismic activities typically include towing high-volume airguns behind ships and firing intense impulses of compressed air often as loud as explosives about every 12 seconds, 24 hours a day -- for up to months on end. This acoustic smog disrupts vital life functions for marine wildlife.

And the large scale of this exploration means activities off the coast of Virginia could affect endangered species in the ocean near southern New England all the way down through the Carolinas. The amount of potential activity is enormous: The Bureau of Ocean Energy Management has already received permit applications to run hundreds of thousands of miles of survey lines during the pre-leasing phase alone.

Take action now to urge the agency to reject the proposal, protect marine ecosystems and keep seismic exploration out of the Atlantic.
Please accept these comments on the Programmatic Environmental Impact Statement for geological and geophysical activities off the mid-Atlantic and southeastern coasts. I have serious concerns about the Bureau of Ocean Energy Management's intention to permit high-intensity seismic surveys in the Atlantic region -- not only because of the potentially catastrophic harms of outer continental shelf drilling, but also because of the significant environmental damage created by airgun exploration itself.

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It is beyond dispute that sound is a fundamental element of the marine environment. Whales, fish and other wildlife depend on it for breeding, feeding, navigating and avoiding predators -- in short, for their survival and reproduction. It's no exaggeration to say that BOEM's proposal would dramatically degrade the acoustic environment along most of the East Coast.

Even according to BOEM's own estimates -- which significantly understate the harm -- oil and gas activity would injure up to 138,500 marine mammals and disrupt marine mammal feeding, calving, breeding and other vital activities more than 13.5 million times over the next eight years alone.

The environmental impact statement itself has significant deficiencies. It fails to assess the far-reaching, cumulative impacts of airgun blasting on marine mammal communication. It doesn't incorporate new studies demonstrating that marine mammals are more susceptible to hearing loss than previously believed. And, despite acknowledging that airguns can cause wide-scale displacement of fish species -- disrupting spawning and reproduction, altering migration routes, impairing feeding and dramatically reducing catch rates, it assumes without support that effects on both fish and fisheries would be localized and "minor."

BOEM's analysis of alternatives is no more credible. The fundamental problem is that the agency simply does not take the problem of cumulative, sublethal impacts seriously. And misrepresenting the scale and potential significance of the impacts, it fails to consider alternatives and mitigation adequate to address them. It does not even attempt to identify biologically important areas within the enormous activity area, aside from critical habitat for the right whale and loggerhead sea turtles. It does not attempt to reduce the extraordinary amount of activity by restricting exploration from areas that are unlikely to be leased, beginning with important Navy training areas, or try to reduce the environmental footprint of the activity that does occur. It fails even to devise a long-term monitoring plan, which is essential to any meaningful adaptive management program.

Please keep seismic activities out of the mid- and south Atlantic Ocean.


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