Mitigation Measures
Mitigation measures are implemented to reduce real threats to marine species. The EnerGeo Alliance supports seismic survey mitigation measures that are grounded in the best available science and consistent with existing practices that are proven to be effective and operationally feasible. However, we do not support mitigation measures that have no basis in fact or science or aimed at addressing presumed but unproven effects that have not occurred nor are projected to occur.
More than five decades of extensive worldwide seismic survey activities and scientific research indicate that the risk of direct physical injury from sound to marine mammals is extremely low. Additionally, there is no scientific evidence demonstrating biologically significant negative impacts on marine mammal populations.
The energy geoscience industry supports utilizing effective mitigation measures based on corresponding levels of potential risk or significant potential impacts on marine animals. Such an approach helps to ensure that the scope of mitigation measures implemented in the field are appropriate to the level of potential risk and specific to the local population of marine animals.
Stewardship is a priority for the energy geoscience industry and part of its core values. The seismic industry is committed to conducting its operations in an environmentally responsible manner and utilizes mitigation measures, such as exclusion zones, soft-starts and protected species observers to further reduce any possibility of impacts to marine populations.
For example, the energy geoscience industry takes into consideration the health of the North Atlantic right whale population and its interaction with proposed seismic surveys on the United States Atlantic Outer Continental Shelf. However, the long-recognized and documented risks to the species are attributed to vessel strikes and fishing gear entanglement and not from sound generated during seismic survey and other exploration operations. There are no documented injuries, deaths or significant disturbances resulting from the use of seismic survey air sources. Because seismic vessels travel at slow speed while conducting surveys (typically half of the current 10-knot regulatory limit), there is little to no risk of a vessel strike. Further, there is no valid reason to apply or expand closure areas, designed to protect against fishery or shipping interactions, to seismic surveys when there is no evidence of adverse impacts from those surveys.
If implemented on a case-by-case basis, closures should be limited to areas where seismic surveys pose a plausible, documented potential for risk to the species of interest. According to the United States Endangered Species Act (ESA), critical habitat consists of spaces required for life processes such as shelter, feeding and reproducing. Under this definition, closure areas should not encompass expanded swaths of “precautionary” territory.
Required levels of protection and mitigation standards should be risk-based, practicable and equally applied to all ocean users based on the relative risks posed by each activity.
References
- Seismic Surveys & Marine Mammals
- IAGC/IOGP Recommended monitoring and mitigation measures for cetaceans during marine seismic survey geophysical operations
- Seismic Surveys and Fish Fact Sheet
- Seismic Survey Fact Sheet
- 23 January 2017 – IAGC & API comments on Revised Application for Marine Mammal Incidental Take Regulations for Geophysical Surveys in the Gulf of Mexico
- 29 November 2016 – IAGC & API comments on Draft Programmatic Environmental Impact Statement for Geological & Geophysical Activities on Gulf of Mexico Outer Continental Shelf