Comments need to be submitted by October 15. Below is what I sent. Feel free to excerpt from my letter in writing your own.
P. Michael Payne
Chief, Permits and Conservation Division
Office of Protected Resources
National Marine Fisheries Service
1315 East-West Highway
Silver Spring, MD 20910
To the National Marine Fisheries Service:
I ask that you deny the Incidental Harassment Authorization
for which Pacific Gas & Electric has applied in connection with its seismic
testing project.
The National Science Foundation’s draft Environmental Assessment
differs substantially in its estimates of marine mammal take from the Final
Environmental Impact Report adopted by the State Lands Commission in granting
the permit for this project. The EA states:
“It is unlikely that the
proposed action would result in any cases of temporary or especially permanent
hearing impairment, or any significant non-auditory physical or physiological
effects. Some behavioral disturbance is expected, if animals are in the general
area during seismic operations, but this would be localized, short-term, and
involve limited numbers of animals.”
The SLC FEIR specifically notes
Significant impacts on Harbor porpoises, Fin whales, Humpback whales, Blue
whales, Bottlenose dolphins and Southern sea otters. This discrepancy needs to
be addressed before an IHA is considered.
The wide range of marine
mammals being affected is unacceptable and far outside the concept of
‘incidental harassment’ as defined: small numbers that will have a negligible
impact on the species or stocks. The impact on the food species for these large
marine mammals should also not be overlooked. If their food is destroyed by the
seismic blasts, which may well happen, the area will become useless to them and
they will be forced to find other feeding areas.
The report identifies substantial ‘impacts’ to marine
mammals and commercial fishing, as well as air pollution. The table on page
4.4-79 of the EIR specifies Level A Take of marine mammals, all of which are
protected under the Marine Mammal Protection Act. Many are also protected under
the Endangered Species Act. The fish, fish eggs and fish larvae that will be
destroyed are the food these animals require. When that is gone, the mammals
will leave.
Northern elephant seals are dismissed in a couple of
paragraphs. "The northern elephant seal is present year-round off of
central California; however, because they spend very little time at the surface
and forage mostly offshore, at-sea sightings are rare." (p. 87) No further
concern is expressed. In fact, elephant seals spend most of their time deep in
the ocean, where the killing blasts will be directed. The time period, from
November 15 through December 31, when PG&E has been approved to blast,
adult males are returning to the Central Coast from Alaska for the breeding
season.
The level of sound blasts from the air guns isn’t just loud,
it’s deafening, 250 decibels. David Sneed, environment reporter for the San
Luis Obispo Tribune, described it as "There is no everyday equivalent for
that level of sound. Most decibel charts list the loudest sound as a military
jet aircraft taking off at 140 decibels."
The suggestion is often made that the animals can simply be
chased out of the area. Blair Jones of PG&E claims that "As they (the
boats) come into an area, they'll start emitting low-pulse sounds to warn
marine life in the area. Those sounds will slowly ramp up until we get to the
level that's needed to perform the survey."
The notion that marine mammals can be harmlessly chased out
of the immediate area is misleading. It’s a direct violation of the Marine
Mammal Protection Act, for good reason, Level B harassment. An IHA cannot
change that. This is these animals’ habitat. They live there because their food
is there and they navigate to their breeding grounds via these areas. Where are
they supposed to go? Someplace where there is no food, or be sent off their
migration routes to find other ways to their homes?
Northern Elephant Seals will be actively migrating through
the area during November and December. Juveniles will be making their way to
the beaches for a needed rest. Blasted away from their rookeries, will they
find other beaches? Or will they swim off and die? Adult males will be
returning in late November and December. They swim deep and are seldom seen at the
surface. That doesn’t mean they aren’t there. It means they are right in the
air gun target zone. They need to get on the beach to prepare for the mating
season. What happens when they can’t get to the beach, or their internal organs
are liquefied? Will they cancel breeding season? Not knowing the answers to
these questions makes issuing an IHA impossible.
PG&E spokesmen stated at the State Lands Commission
hearing that operations would be shut down if any marine mammal was within 1.1
miles. With hundreds of thousands of marine mammals living off our coast, that
boat will always be within that radius of whales, seals, sea lions and otters. They
cannot possibly assure that the blasting will not be within that range,
considering the deep-diving mammals that live and migrate through the area,
even in the daytime. At night, it’s even less possible to see them and stop
operations.
Pacific Gas & Electric has been given permission to
blast the coast with 250-decibel air guns, 24/7, for 33 days and nights. The
justification for this elaborate, expensive and destructive project is:
“PG&E’s Geosciences staff believes that data gathered from the additional
studies that comprise the Project would improve characterizations of these
fault zones and allow PG&E to refine estimates of the frequency and
intensity of ground motion that is likely to occur in the area surrounding and
including the Diablo Canyon Power Plant. This information may also improve
assessments of the potential seismic hazard at the DCPP.”
The original proposal was for a longer period of blasting
but was not assured of providing data that would provide significant
information. The reduced time period and area covered is even less likely to
produce useful information.
The data PG&E hopes (but can’t be certain) this project
will produce will not make Diablo Canyon Nuclear Plant any safer. No
modifications are contemplated, no changes will be made. The data will be used
to create an improved, 3-D computer model. PG&E reps are enthusiastic over
how they would be able to rotate and slice this CAT-scan-like image, so
superior to the conventional 2-D X-ray images they find so limiting. I don’t
underestimate the value of computer modeling in predicting future catastrophe,
but weighing the certain damage against the dubious advantages of this
technology makes Incidental Take unacceptable and unjustified in connection
with this project.
Thank you.
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