In 2014 the Bureau of Ocean Energy Management issued an environmental impact statement assessing the effects of seismic surveys in the Atlantic. The EIS was to be used when making decisions on requests from companies for permits to conduct seismic surveys. But the document does not meet the legal requirement to fully assess the significant impacts of major proposals.

The most serious flaw in the EIS is a failure to evaluate the cumulative effects on marine life from the noise of multiple seismic surveys and other ocean activities. Although the document lists the estimated number, frequency, duration and linear extent of expected airgun surveys, it does not factor that information into the analysis.

For example, the analysis focusing on marine mammals states that highly mobile cetaceans will “move freely” to avoid airgun noise, and that exposure to the noise “would be somewhat localized and temporary in duration ... .” In other words, the analysis fails to consider the effects on animals having to repeatedly flee from airguns.

It is also counterintuitive to claim that marine mammals can avoid airgun noise. The animals would have to hear the noise, then react by fleeing from sound source. But the harm will have been done.

If acoustic exposures are infrequent, a marine mammal would likely recover and resume normal behavior once it is a sufficient distance from the airgun array. But because the acoustic energy pulses are audible hundreds and, in some cases, thousands of miles from the noise source, marine mammals in the survey area will at times be exposed to multiple, round-the-clock airgun activities and will probably experience some airgun noise most days of the year. Many animals would become exhausted from this repeated exposure to harassing noise because they will not have had time to recover the energy expended when fleeing. There is a limit to how much abuse a marine mammal, or any animal, can take without dire consequences. These are significant, cumulative impacts that are not addressed in BOEM’s analysis.

Cumulative impacts may be significant for a pod or an entire marine mammal stock, not just for individuals. The EIS does not discuss the risk to the sustainability of affected marine mammal populations when exposed to all acoustic sources and other impact-producing activities in and adjacent to the survey area. Noise from many sources over a large area for many months could reduce the population of a particular marine mammal species below a threshold from which it is unable to recover.

BOEM is evaluating requests from five companies to conduct seismic surveys in the Atlantic. If the duration and extent of the planned surveys are considered together, along with other anthropogenic noise in the ocean, a rigorous analysis would conclude that unacceptable, significant impacts would be experienced by marine life. On that basis, BOEM’s 2014 EIS is inadequate. The agency should deny the five permits.

Richard Wildermann

Privateer Creek Road

Johns Island