June 8, 2019
Mr. Dan Burger
Office of Ocean and Coastal Resource Management
1362 McMillan Avenue
Charleston, S.C., 29405
Re: Comments on WesternGeco federal permit application
Dear Mr. Burger,
Since January of 2015 the South Carolina Small Business Chamber of Commerce has been on the record opposing the exploration and drilling for oil and gas in the Atlantic Ocean.
Our organization and 16 South Carolina’s coastal cities filed a lawsuit in December of last year contending that the National Marine Fisheries Service (NMFS) improperly approved Incidental Harassment Authorizations (IHAs) for seismic companies petitioning to conduct exploration in the Outer Continental Shelf off our East Coast. This lawsuit, quickly joined by the South Carolina Attorney General, was later merged with a similar lawsuit filed by conservation organizations.
During the comment period for the IHAs, comments to the NMFS were submitted by the Business Alliance for Protecting the Atlantic Coast (BAPAC) on June 5, 2017. These comments were submitted on behalf of the 42,000 Atlantic Coast business supporters of BAPAC, including the South Carolina Small Business Chamber of Commerce and our supporters.
Our organization’s objections, as submitted by BAPAC, to the approval of the IHAs addressed these points:
- Mitigation and Monitoring Requirements Insufficient for Protecting Marine Mammals
- Mitigation and Monitoring Requirements Nonexistent for Protecting Fish and Invertebrates
- Impact on the Base of the Ocean Food Chain Ignored
- Analysis of Impact of Multiple Seismic Airgun Surveys Understated or Nonexistent
- No Consideration or Compensation for Lost Revenue to Other Businesses Due to Seismic Surveys
- Alternative Technology: Research Knowledge Not Up-To-Date and Viable Alternatives Not Pursued
Attached are the BAPAC comments which I am submitting to your office to be considered regarding the WesternGeco federal permit application. Also attached are the comments from hundreds of individual small business owners along the Atlantic Coast, including South Carolina, describing their opposition to seismic testing, comments that were provided to the NMFS during the IHA comment period.
The South Carolina Small Business Chamber of Commerce submitted supplemental comments to the NMFS on April 19, 2018, regarding the IHAs. While these comments fell outside of the official comment period, new information was obtained about grave threats that seismic testing might pose. These comments, which are also attached for consideration in this process, describe the extent of munitions (conventional and chemical) and radioactive waste drums that have been dumped along the Atlantic Coast, including off the South Carolina Coast, and the potential for seismic testing to release toxic chemicals into the ocean waters.
More recently, the Israel Nature and Parks Authority issued a preliminary report (May 22, 2019) on a mass stranding event of sea turtles on the coast of Israel in January of this year. This report is attached.
While a final report is expected next month, initial CT examinations of live injured turtles indicates that the injuries were most likely due to “strong impulse sound”:
CT scans of live injured sea turtles revealed that 83% (19 of 23 examined) showed symptoms of soft tissue trauma: pulmonary hemorrhage and accumulation of fluids in the middle ear (Fig. 4). Such symptoms are consistent with shock-wave trauma, suggesting a fatal exposure to a yet undetermined strong impulsive sound source, such as underwater explosions, on a significant level.
While the exact source of the impulsive sound source is yet to be determined, the only public information on the source points to seismic airgun blasting:
…during the time in question, a 3D seismic air-gun survey for gas exploration was conducted in two areas within Israel’s EEZ, about 40 to 90 kilometers offshore.
The Israel Nature and Parks Authority provides one tentative explanation for the trauma the sea turtles experienced:
…in this scenario, only a moving blast source, capable of producing many underwater shock waves, while covering large areas, may suffice to explain the large number of stranded sea turtles.
Clearly, this would be a description of seismic exploration for oil and gas.
If the final report concludes that seismic impulses were the most likely cause of this mass stranding, it would be a strong rebuttal to the seismic and petroleum industries’ insistence that there is no evidence that seismic exploration is harmful to the ocean’s fish and invertebrates. It would then follow that seismic airgun blasting should be considered to be economically harmful to our commercial fishing industry.
In addition, a finding that the impulses created by seismic blasting are strong enough to damage living tissue is also relevant to the South Carolina Small Business Chamber of Commerce’s concern about seismic airgun blasting posing a risk of releasing toxic chemicals into the water from the thousands of deteriorating munitions and radioactive waste containers littering the Atlantic and South Carolina coastal waters.
Based on all the concerns addressed in the attached documents, we ask that the Office of Ocean and Coastal Resource Management (OCRM) to find that the federal permit application submitted by WesternGeco be found to be not consistent with the SC Coastal Management Program (SCCMP).
Finally, given the confusion regarding the dates of this comment period, we ask that the OCRM take legal action against the U.S. Department of Interior and/or Bureau of Ocean Energy Management should OCRM find that the petition in question is inconsistent with the SCCMP but the federal agencies reject the finding due to OCRM missing the deadline for input. Such a scenario would have the federal government concluding that the petition in question is consistent with the SCCMP despite the opposite conclusion of the OCRM.
Frank Knapp Jr.
President & CEO