Dear All,

On behalf of several NGOs, NRDC has submitted extensive comments to the U.S. 
Bureau of Ocean Energy Management, about its plan to open up the U.S. 
mid-Atlantic and south Atlantic to seismic surveys.

We are deeply concerned about the government's analysis of marine mammal 
impacts.  The fundamental issue, as we see it, is that the agency does not take 
the problem of cumulative, sublethal effects seriously; and misapprehending 
their scale and potential significance, it fails to consider alternatives 
sufficient to address it.  BOEM does not attempt to identify biologically 
important habitat for protection, aside from a portion of North Atlantic right 
whale habitat; does not attempt to reduce the enormous amount of activity that 
is contemplated, e.g., by restricting exploration from areas that are unlikely 
to be leased; and fails even to devise a long-term marine mammal monitoring 
plan for the region.  Together with the greater impacts recently predicted from 
Navy activity, populations in the U.S. Atlantic will be hard hit.

Please write me if you'd a copy of our comments.  BOEM plans to make a final 
decision in November of December.  We'll keep the community apprised as this 
important issue moves forward.

Best,
Michael


Michael Jasny
Senior Policy Analyst
Natural Resources Defense Council
4479 W. 5th Avenue
Vancouver, BC  V6R1S4
tel. 604-736-9386
mob. 310-560-5536
fax 310-434-2399
[email protected]<mailto:[email protected]>


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