Environmental Stewardship Concepts, LLC

www.estewards.com

Environmental Stewardship Concepts, LLC 1006 Pump Rd. Henrico, VA 23238 Phone-804-741-2922 Fax- 804-741-2922 [email protected]

June 28, 2012

Gary D. Goeke Chief, Regional Assessment Section Office of Environment (GM 623E) Bureau of Ocean Energy Management Gulf of Mexico OCS Region 1201 Elmwood Park Boulevard New Orleans, Louisiana 70123-2394

Dear Mr. Goeke,

My name is Dr. Peter deFur, and I am owner and president of the consulting firm Environmental Stewardship Concepts, LLC and a member of the Mid Atlantic Fishery Management Council. I have 40 years of experience in the environmental field and worked on the OTA analysis of oil and gas development off the Mid Atlantic coast in the 1970s.

I have reviewed the Programmatic Environmental Impact Statement for the Mid- and South Atlantic planning areas. It is my strong belief that the most favorable option is C, with strict conditions and controls for the few cases in which oil and gas exploration permits are granted. This recommendation is based on the evidence of impacts on the coastal resources and the substantial efforts by many organizations to maintain sustainable resources and protect others.

These conditions and controls are what will make option C viable. First, there should be no exploration during whale migration season, or during turtle spawning and egg-laying times. Any activity on an Essential Fish Habitat (EFH) must bring an observer to document the exploratory activities and their interactions with fisheries. Any ship strikes of protected species must result in immediate return to port, with no questions asked, and an immediate report to NMFS and USFWS.

Scallop and surf clam grounds are two of the most important fishery resources; as such, no exploration work should be conducted on such sites, and the oil and gas industry must fund research on the impact of any and all exploration activities prior to the initiation of any exploration work. If any work is carried out near trawling areas, a vessel or commercial expert fisherman must be hired to guide them clear of schools of fish that must be avoided with a wide area of clearance. www.estewards.com The scientific literature provides evidence that air guns and other loud acoustic disturbances have adverse impacts on various living coastal resources, including, but not limited to squid, mammals, bivalves and shrimp. Little research has been published on the two commercial bivalves, scallop and surf calms, that are among the most valuable fisheries, measured by the value of landings.

A study done by J.L. Fewtrell and R.D. McCauley found a consistent response of alarm from various species of captive marine fish and one species of squid, when exposed to the noise of an airgun exceeding 147–151 dB re 1 μPa SEL. The louder the noise became, the more significantly the alarm response was observable, causing increased energy expenditure and behavioral alteration, whose effects could long ranging with over-time exposure to the noise (Fewtrell and McCauley 2012).

Another study done on sperm whales in the Gulf of Mexico yielded similarly alarming results, showing behavioral changes in the feeding processes of these whales. In addition, the whales did not attempt to avoid the “ramp-up” noise of warning produced by the air gun, calling into question the, “efficacy of ramp-up as a mitigation protocol” (Miller, Johnson, Madsen, Biassoni, Quero, and Tyack 2009). In short, there has simply not been enough study done to examine the long-term effects of the noise produced by air guns on the animals found in the Mid- and South Atlantic region, but the results we do have are distressing.

I hope that you will consider this matter carefully before deciding on a course of action. Our actions today dictate the effects that our wildlife will face tomorrow. We must consider migratory mammals, finfish, turtles, squid, bluefin tuna, and a whole host of other animals that will feel the effects of whatever course is taken. I encourage you to consider Option C as the most viable option available.

Sincerely,

Peter L. deFur, Ph.D Environmental Stewardship Concepts, LLC

References www.estewards.com Fewtrell, J. L., and R. D. McCauley. "Impact of Air Gun Noise on the Behaviour of Marine Fish and Squid." Marine Pollution Bulletin 64.5 (2012): 984-93. SciVerse. Elsevier BV, 3 Mar. 2012. Web. 28 June 2012.

Miller, P. J.O., M. P. Johnson, P. T. Madsen, N. Biassoni, M. Quero, and P. L. Tyack. "Using At-Sea Experiments to Study the Effects of Airguns on the Foraging Behavior of Sperm Whales in the Gulf of Mexico." Deep Sea Research Part I: Oceanographic Research Papers 56.7 (2009): 1168-181. SciVerse. Elsevier BV, 17 Mar. 2009. Web. 28 June 2012.