Helen M. Golde, Acting Director
Office of Protected Resources
National Marine Fisheries Service
1315 East-West Highway, Room 13115
Silver Spring, MD 20910
Dear Ms. Golde,
Oil and gas activities, including seismic testing and exploration drilling, pose significant threats to marine mammals in the Arctic Ocean. Noise and disturbance from these activities can introduce stress, alter behavioral patterns, and interfere with feeding and communication among these animals. Although the Marine Mammal Protection Act requires a precautionary approach, the Supplemental Environmental Impact Statement (SEIS) prepared by the National Marine Fisheries Service (NMFS) and the Bureau of Ocean Energy Management (BOEM) fails to ensure that Arctic marine mammals will receive adequate protection.
Under federal law, impacts on marine mammals must be no more than “negligible” and limited to harassment of only “small numbers” of animals. Yet several alternatives under consideration would allow up to eight exploratory drilling programs in the U.S. Arctic each year. Some of these alternatives could cause “major adverse” impacts to bowhead whales, including high-intensity, regional-scale effects. The SEIS concludes that all action alternatives would adversely impact bowhead and beluga whales.
Arctic marine mammals deserve better protection. NMFS and BOEM should revise the SEIS so that it takes a more precautionary approach consistent with the requirements of the Marine Mammal Protection Act. Among other changes, NMFS and BOEM should:
- create a “noise budget” to better address the overall level of industrial noise;
- expand the use of time/area closures to all alternatives;
- incorporate NMFS’s updated acoustic criteria into the analysis; and
- collect and synthesize scientific information and traditional knowledge to better understand and evaluate long-term and cumulative effects of oil and gas activities, other industrial activities and climate change.
No one has demonstrated the ability to effectively clean up a major oil spill in the Arctic, and the damage from such a spill could be catastrophic. The Arctic’s Chukchi and Beaufort seas help to regulate our climate and provide vital habitat for iconic wildlife like walruses, polar bears, bowhead whales and migratory birds.
Please revise the SEIS to better protect marine mammals and the Arctic marine environment.
Ocean Conservancy and Your Name