API outlines initial concerns with BOEM’s draft gulf PEIS

Mitigation measures that would require halting of oil and gas operations when dolphins are in the vicinity and proposed minimum separation distances for seismic surveys running simultaneously are among the American Petroleum Institute’s biggest initial concerns with the US Bureau of Ocean Energy Management’s draft programmatic environmental impact statement (PEIS) for the Gulf of Mexico (OGJ Online, Sept. 29, 2016).

“Our initial read shows that the restrictive nature of some of the proposed mitigations would threaten the economic and operational feasibility of performing seismic surveys in the [gulf],” API Offshore Senior Policy Advisor Andy Radford said.

“We have been performing seismic surveys safely with no demonstrated harm to marine mammal populations for decades. Neither our operational experience nor the best available science would dictate the level of precaution proposed in certain alternatives,” he told reporters Oct. 13.

API also is “deeply troubled” by proposals to reduce the number of seismic surveys in the gulf by 10% or 25%, Radford said. This is a problem not only because of potentially lower future production, but also because the reduction in the number of seismic surveys and wells drilled would negatively affect the region’s economy and the industry’s ability to create jobs, he said.

BOEM’s method of calculating the number of “takes”—a term from the 1972 Marine Mammal Protection Act that includes an injury or behavioral disruption—also needs much more scrutiny, Radford said. The law contemplates two levels of impacts, for example: one on the individual animal, and the other a cumulative effect on overall populations, he said.

“Historically, the models used have been overly conservative and do not take into account the effective mitigation measures used by industry,” he said. “The result is astronomically and unrealistically high numbers for potential takes that are then misused and sensationalized by groups opposed to energy production. The modeling used should accurately reflect the best science and research and our operational experience, which indicates that seismic surveys have little-to-no impact on marine wildlife populations.”

How BOEM estimated impacts

Radford said BOEM took a proposed number of industry surveys over the next 10 years, and modeled how many animals would be exposed to sound for a total of 32 million. But not all of the marine mammals would necessarily be subject to a take under the MMPA. “When we looked at this the last time, BOEM chose the most conservative assumption and built on other conservative assumptions, creating numbers that did not reflect what our experience shows,” he said.

API also sees no need for offshore oil and gas operations, which already halt when whales show up, to shut down when dolphins arrive, Radford said. “They come right into the area and don’t seem to react to noise. Our research shows they can shut off their hearing and not be affected,” he said.

Requiring a minimum separation distance when seismic surveys are running simultaneously also does not appear to be justified, he said. BOEM’s analysis for its earlier Atlantic Seismic Final EIS concluded that a proposed 25-mile separation distance would only slightly reduce potential impacts to marine mammals and noted that there was “uncertainty” surrounding its effectiveness as a mitigation measure, Radford said.

History has shown repeatedly that exploration and development activities generally lead to higher resource estimates, he said. Estimated recoverable crude oil resources in the gulf jumped fivefold to 48.4 billion bbl in 2011 from 9.57 billion bbl in 1987 with more recent seismic data acquisition, technological advances, and additional exploratory drilling, Radford said.

Possible new seismic restrictions in the gulf could hamper not only the oil and gas industry, but also the US Geological Survey, the National Science Foundation, and the offshore wind industry, he warned.

“Additionally, a rigorous environmental analysis and permitting process ensures that seismic surveys are properly managed and conducted so they have minimal impact on the marine environment,” Radford said. “There is no evidence that the sound produced by exploring for oil and gas with seismic surveys has resulted in any physical or auditory injury to a marine mammal or impacted marine mammal populations in the Gulf of Mexico.”

Contact Nick Snow at nicks@pennwell.com.

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