Comments related to seismic surveys in the Atlantic that API and two other associations will submit to federal officials stress a number of important points about the underwater tests used to establish the size and location of oil and natural gas reserves:
Importance of U.S. Offshore Energy
By federal estimates, the Mid- and South Atlantic outer continental shelf (OCS) holds at least 4.59 billion barrels of oil and 38.17 trillion cubic feet of natural gas. Federal law calls for “expeditious and orderly development” of the OCS “subject to environmental safeguards.” Congress enacted that law to:
“… achieve national economic and energy policy goals, assure national security, reduce dependence on foreign sources, and maintain a favorable balance of payments in world trade.”
Earlier this year President Trump signed an executive order that said:
“[It] shall be the policy of the United States to encourage energy exploration and production, including on the Outer Continental Shelf … while ensuring that any such activity is safe and environmentally responsible.”
Safely and responsibly developing key parts of the Atlantic OCS is in the national interest – and orderly, scientific, responsible seismic testing is integral to that development.
Seismic Surveying is Safe
The best available scientific information shows that proposed surveying will have no more than a negligible impact on marine mammal species or stocks. For a number of years industry operators in the Gulf of Mexico have complied with measures to protect marine mammals, and by all accounts these measures have worked. Indeed, the federal Bureau of Ocean Energy Management has acknowledged the point a couple of times (see here and here) and said in a recent Draft Programmatic Environmental Impact Statement for the Gulf that:
“G&G [geological and geophysical] surveys have been going on in the northern GOM for many years, with no direct information indicating reduced fitness in individuals or populations.”
API, the International Association of Geophysical Contractors and the National Ocean Industries Association say in draft comments that while some of the safety measures proposed by federal officials are impractical and need to be revised or eliminated, safeguards used by seismic operators will be effective in minimizing or avoiding incidental harm to marine mammals:
Insofar as we are aware, no seismic activities that have received [Marine Mammal Protection Act] incidental take authorizations have caused any impacts beyond a temporary change in behavior for individual animals or any adverse consequences to marine mammal species or stocks.
The groups say the increasing efficiency and precision of seismic surveying helps reduce risks to safety and the environment that may be associated with offshore development:
[M]odern geophysical imaging reduces risk by increasing the likelihood that exploratory wells will successfully tap hydrocarbons and by decreasing the number of wells that need to be drilled in a given area, thereby reducing associated safety and environmental risks and the overall environmental footprint for exploration. As technology advances, the geophysical industry can continue to reduce drilling risk and increase potential production. Just as physicians today may use MRI technology to image an area that previously had been imaged by X-ray technology, geophysical experts are actively using and enhancing the most modern technology to make improved evaluations. Moreover, because G&G activities are temporary and transitory, seismic surveying is the least intrusive and most cost-effective means to determine the likely locations of recoverable oil and gas resources in the Atlantic OCS.
Reasonable Mitigation Measures Needed
The groups write that some of the proposed mitigation measures aren’t “consistent with the best available science and are unnecessarily overbroad.” A couple of examples:
- The exemption from the shutdown requirements for small dolphins approaching a seismic vessel is too narrow and won’t meaningfully alleviate the substantial number of dolphin-related shutdowns that will occur. The exemption should apply to all dolphin species regardless of dolphin behavior, the groups write.
- A proposal for required shutdowns for certain types of marine mammal observations “at any distance” is arbitrary. “As written, this measure cannot reasonably be implemented because it is vague and unbounded,” they write.
The need to safely develop our offshore oil and natural gas is strategic – for jobs, the economy and future energy security. It starts with reliable, scientific information from seismic surveying that allows exploration and development to occur with the smallest possible footprint, helping to protect the marine environment. Seismic technology is safe, and seismic operators have demonstrated they can do their work with minimal impacts on marine mammal populations.
Recommended changes to the proposed mitigation measures should be accepted, and federal officials should move expeditiously to clear the way for critically important assessments of our OCS energy reserves.
By Mark Green
Originally posted July 21, 2017
Energy Tomorrow is brought to you by the American Petroleum Institute (API), which is the only national trade association that represents all aspects of America’s oil and natural gas industry. Our more than 500 corporate members, from the largest major oil company to the smallest of independents, come from all segments of the industry. They are producers, refiners, suppliers, pipeline operators and marine transporters, as well as service and supply companies that support all segments of the industry.