The EnerGeo Alliance and the energy geoscience industry are committed to conducting operations in an environmentally responsible manner. Extensive time-area closures that may or may not apply to each applicant’s survey plan fail to provide additional environmental protection for marine species and place unwarranted burdens on operators. Usually, designation of a time-area closure is based on a specific reason such as protecting a coral reef or a whale calving area. The EnerGeo Alliance supports scientifically-based closure restrictions on a case-by-case basis to ensure the continued health of the marine ecosystem.
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.