Concerns and Risks of PG&E's Proposed
Central Coastal California Seismic Imaging Project
by Carol Georgi and Karl Kempton
Page 2
Discussion of the Significant References not included in the EIR
1 — SEISMIC
The EIR has no mention of the overall macro forces on the Pacific Plate, which is west of the San Andreas Fault. These complex forces are caused by land masses on top of microplates that are now part of the Pacific Plate. The southern land masses press against each other because of the northward movement of the Pacific Plate. These in turn press against the local land masses also riding on a captured mico plate now part of the Pacific Plate. This is creating faults and subduction between the coast and the Santa Lucia upthrust block. Note the following:
The Pacific Plate continues its northwest migration subducting under Alaska. As it does so, it rotates the Western Transverse Block on top of the Arguello Microplate to our immediate south. It is bordered on its eastern side by the Eastern Transverse Block, on the western side by the Channel Islands with the Ventura-Santa Barbara Basin in the middle, and on its northern side by the Arguello Canyon. The Channel Islands at one time were on the mainland. They have been rotated over 90 degrees. Also, Baja on top of its microplate, now presses against this Transverse block causing folding and uplift.
We live on a fragment of the Farallon Plate, the Monterey Microplate. It is bordered on the west by the Santa Lucia Bank and the Santa Lucia Escarpment. This microplate captured land mass is from the North American Plate, which is east of the San Andreas Fault. The San Andreas Fault is the eastern border of our land mass that rides the Monterey microplate northward as part of the Pacific Plate.
This land mass is deformed with a subsistence slant from the coastline to the Santa Lucia Bank caused by pressures from the rotating Western Transverse Block. At the eastern edge of the Santa Lucia Bank is the Santa Lucia Fault. The Bank is tilted with the uptrust on its eastern most side. Diagrams (see immediately following links) illustrate the magnitude of the crack in our land mass. Running nearshore is the Hosgri Fault, another huge crack in this land mass.
There are many more fault lines known and probably unknown or if known not nearly studied in enough detail. See page 5 of Chapter 2 and Microplate capture, rotation of the western Transverse Ranges . . . (In PDF format.) (See Maps in Slo Coast Journal article)
2 — MARINE FISH LIST
The EIR is lacking in detailed listings of marine fish in the sonic blasting area and areas adjacent that will also be negatively impacted. For example:
• See (as counted by the pdf doc) pp 98-99 list of fish taken between Piedras Blancas and Point Buchon and fish list of testing area pp 164-167 Proposed Central Coast National Marine Sanctuary, 1990.
• See pdf pages 77-93: report dated 1973: The Marine Environment in the Vicinity of Diablo Cove with Special Reference to Abalones and Bony Fishes by Burge and Schultz, Marine Resources technical Report No. 19, California Fish and Game
• See fish list of testing area pdf pp 164-167 Proposed Central Coast National Marine Sanctuary, 1990
3 — IMPACT ON WHALES, PORPOISE AND DOLPHINS IS UNDERSTATED
Regarding APM-1 Survey Timing. To be less disruptive to migrating and summer season whales, the survey shall be timed to occur during the months of September through December:
. It fails to mention that 13 whale, porpoise and dolphin species feed at the Santa Lucia Bank in the fall. These are dependent upon the local documented internationally and nationally significant and robust diversity and density of marine life.
. It fails to mention that dense populations of whale and porpoise species at the same time feed at the Davidson Seamount in the MBNMS. Again, these are dependent upon the local documented internationally and nationally significant and robust diversity and density of marine life.
Question: When the sonic blasting begins and scatters these migrating populations of whales, porpoises and dolphins, where do they go for their dependent food?
• The sonic blast impacts on whales, porpoises and dolphins are understated. Consider these excerpts from Simeon Tegel's, "Peru's Massive Dolphin Die-off Sparks Concern Over Oil Search," published by GlobalPost.com http://www.globalpost.com/dispatch/news/regions/americas/120417/peru-massive-dolphin-deaths
Veterinarian Carlos Yaipen-Llanos stated that the sound of the seismic testing can travel more than 100 miles in the open seas and the frequency fell right in dolphins' normal hearing range.
Patricia Majluf, the deputy minister of fisheries, told the Peruvian congress last week that BPZ executives in a meeting had been unable to give her clear answers regarding the effects of their oil exploration on marine mammals.
"BPZ's environmental impact study should have included a detailed description of the area of influence and the level of decibels that there would be in the impact zone," she added.
"Regrettably, similar deaths have also been reported globally, including Brazil and various states on the Atlantic Coast of the United States, more recently Cape Cod, Massachusetts," the statement read.
Sue Rocca, an American marine biologist with the Whale and Dolphin Conservation Society, the leading international environmental group dedicated to marine mammals, agreed with Yaipen-Llanos' suspicions.
"There are all the telltale signs of seismic [testing]" she told GlobalPost, adding that US Navy divers had been known to have seizures after being exposed to seismic testing.
"It is an extremely painful experience for dolphins. They are very acoustic animals and these are huge, frightening sounds. For years, we thought marine mammals couldn't get the bends. Unfortunately, we now know that that is not true."
4 — THIS EIR LACKS CONTEXT OF THE INTERNATIONAL AND NATIONAL SIGNIFICANT DENSITIES AND DIVERSITIES OF SPECIES IN THE BLAST ZONE, I.E. PROJECT AREA
• The missing assessments
• Most current NOAA biological assessments from the Channel Islands National Marine Sanctuary and the Monterey Bay National Marine Sanctuary are missing.
• Because these assessments are missing, there is no description of the food chain with highly probable disruptions of entire populations. Example: The proposed sonic testing period coincides with the densest brown pelican population in the state. The brown pelicans migrate north from their Channel Islands rookery in the late spring and return in the late fall. In late summer they set up the densest population in the state along the SLO County Coastline before returning to the Channel Island rookery. This population is totally dependent upon the usual marine life patterns of the local waters that will be totally disrupted. This is but one of many species dependent upon the local documented internationally and nationally significant and robust diversity and density of marine life.
1 — Areas of the proposed study, A Biogeographic Assessment off North/Central California in Support of the Cordell Bank, Gulf of the Farallones and Monterey Bay National Marine Sanctuaries
2 — from the SIMoN Sanctuary Integrated Monitoring Network - Regional Sections / Fisheries
a-fish densities
b-seabirds and shorebirds
c-marine mammals
3 — from Channel islands National Marine Sanctuary management Plans documents
a-Draft Management Plan / Draft Environmental Impact Statement:
b-Channel Islands National Marine Sanctuary - Management Plan Review May 2006, APPENDIX C: BIOLOGICAL AND HISTORICAL/CULTURAL
Resources of the Study Area for the Channel Islands National Marine Sanctuary
List of fishes, table C-3 pp C-33 to C-36, List of seabirds, table C-4 pp C-40 to C-47 (See: Channel Islands NOAA)
c - Channel Islands National Marine Sanctuary - Management Plan Review May 2006, where web of life charts may be found for example on pp c-24, c-28,
d-Compare these fish lists report dated 1973: The Marine Environment in the Vicinity of Diablo Cove with Special Reference to Abalones and Bony Fishes by Burge and Schultz, Marine Resources technical Report No. 19, California Fish and Game. see Proposed Central Coast National Marine Sanctuary, 1990 -- pdf pages 77-93
• Regarding APM-1 Survey Timing. To be less disruptive to migrating and summer season whales, the survey shall be timed to occur during the months of September through December:
It fails to mention that 13 whales, porpoise and dolphin species feed at Santa Lucia Bank in the fall. Again, these are dependent upon the local documented internationally and nationally significant and robust diversity and density of marine life
It fails to mention that denser populations of whales and porpoise species at the same time feed at the Davidson Seamount in the MBNMS. Again, these are dependent upon the local documented internationally and nationally significant and robust diversity and density of marine life
• While eggs and larvae sages of fish are doubtfully being 'protected' by timing of sonic blasting, the next growth stage, pre juvenile, is not, thus highly probable destruction of large numbers will occur.
• The EIR comments on the fact that warm water marine life has established itself within the habitat washed by the warm water discharge of DCPP's Once Through Cooling System. The OTC System itself kills over 1.7 billion fish larvae per year, a fact PG&E hid from the public and regulators for nearly 20 years. What will be the death rate of the established warm water life forms when scattered into colder waters by the sonic blasts?
5 — DESTRUCTION OF THE COMMERCIAL AND RECREATIONAL FISHERY
The cavalier and off hand commentary regarding the destruction of the local fishery economy, commercial and recreational, is insensitive at best if it were at least honestly representing this sector of our economy. The landings at San Luis and Morro Bay harbors over the last twenty years have had an extreme downward trend since its peak in 1985. Fish landing value data in the EIR seem to try to ignore the recent upswing in values of landings by providing tables of yearly and monthly averages over a long period as to minimize recent and hard won gains. One could conclude that this is intentional to avoid fair mitigation for loss of income and the associated economic impact multipliers.
The EIR focuses on the fish of present commercial interest forgetting or ignoring, again, the interdependent complex web of life. Commercial fish, as all fish, are dependent on what they eat. The sonic blasting is either going to scatter those who able or willing and injuring or killing those who can not or will not given their particular habit. There is great concern about the destruction of or severe damage to fish ear bones and exploding fish bladders caused by the sonic waves. The entire local fishery ecology will be out of balance.
The length of this disruption is open to debate and most likely to be considerably longer than the EIR hopes. Considerable disruption over a long period of time occurred in the early 1980's due to seismic testing by oil companies. That testing was much shorter in duration and less invasive.
We concur with local fisher families concerns by Lori French as recently published in the San Luis Obispo Tribune.
"The commercial fishermen of Morro Bay and Port San Luis have a list of concerns:
1. The survey will be conducted in Marine Protected Areas and Rock Cod Recovery Zones. These are essential fish habitat where no commercial fishing is allowed by law. Yet PG&E plans to test in these areas.
2. The environmental impact report is based on 1980s low-energy seismic testing done for oil surveys. In the '80s, marine life was affected for three years. This 1980s test was done at a much lower decibel level with only one cable. One fisherman, a commercial diver at the time, recalls being forced out of the water 10 miles away from the sound. (Sound travels 10 times further underwater.)
3. The environmental impact report seems to be flawed, using incorrect blocks or landing areas for commercial fishing as well as dated economic data for our commercial fishing seasons and landings.
4. The environmental impact report states that the air guns should only create a temporary hearing loss to fish and marine mammals. We feel this is incorrect. Fish have ear bones that can be easily shattered, and this would devastate shallow area rock fish. Recovery time was based on East Coast species, not West Coast species.
5. Larvae and fish eggs will be severely damaged or destroyed by this study.
If this study goes on as planned, there will be serious damage to our local economy from money lost from the study's effects on commercial fishing, sport fishing and whale and marine mammal watching. PG&E seems to be unresponsive to negotiations in regards to mitigation of damages."
Lori French, Tribune, April 18, 2012
6. THE EIR DOES NOT ADDRESS THE IMPACTS TO THE MARINE LIFE WITHIN THE TWO NATIONAL MARINE SANCTUARIES BORDERING THE PROPOSED TESTING AREA
The proposed "Central Coast National Marine Sanctuary, 1990," is located between the Monterey Bay National Marine Sanctuary (MBNMS) and the Channel Islands National Marine Sanctuary (CINMS). This unprotected ocean area will become the "killing fields" for marine life when seismic testing begins in September, 2012, and lasts about 82 days. This "gap" between the sanctuaries is connected not only to both the MBNMS and the CINMS, but also to the entire West Coast from Alaska to Baja, California, and to the far reaches of the world by ocean currents and migrating species.
Where will the migrating species feed when they are chased away by seismic testing? The source for the following information is from "Connected by Currents"
California's central coast is located on a migration pathway between the Arctic feeding grounds and the temperate and tropical breeding areas for the most diverse and abundant species of marine mammals in the world, including twenty-seven species of cetacean (whales, dolphins, and porpoises), six species of pinniped (seals and sea lions) and one species of fissiped (sea otter).
The California Current is a slow-moving southward current carrying about 10-trillion gallons of water per hour. Two currents, the Davidson Current and a deeper undercurrent, flow north. When this current runs strong, the current carries animals southward from sub-artic waters. When it slackens in the fall, the surface waters warm and southern species move northward. This ever-shifting mix of species adds to the great diversity of our West Coast national marine sanctuaries. The current serves as a vast, open highway for whales, birds, fishes, and plankton, pelagic seabirds, mammals, fishes, sharks and turtles which follow it on long migrations in search of food or suitable places to nest, spawn, or give birth.
Vast schools of sardines anchovies and hake spawn in the warmer waters around the Channel Islands, then swim north through MBNMS to find plankton to feed on. The small fishes are joined by giant blue whales and other whales that come to feed on krill and various plankton. Salmon spawned in streams along the Olympic Coast follow the current north to the Gulf of Alaska and south to MBNMS and CINMS in search of food. Gray whales traverse the entire coast, passing through both sanctuaries as they migrate from Alaska to Baja, California. Pods of transient orcas travel from the Olympic Coast to Monterey Bay and Channel Islands in spring to hunt gray whale calves as they swim north with their mothers. Elephant seals, sea lions and fur seals roam widely along the coast and far out to sea then return to rookeries in both sanctuaries where they give birth to their pups. Yearly, albacore tuna follow currents across the Pacific and back again. Sooty Shearwaters travel here from as far away as New Zealand; and leatherback turtles migrate from Indonesia.
The result of the sonic blasting will be complete disruption of the balance of the local marine habitat: the web of life and its unique and fragile syncopated food chain.
Included as an addendum to this letter:
Continuation of section 4:
*A detailed overview of the international and nationally significant local waters located between two national marine sanctuaries. Both sanctuary programs have studied these waters in detail. These studies go unmentioned in the bibliography of the EIR.
*Several Marine Sanctuary Articles published in the Slo Coast Journal
7. BIBLIOGRAPHY
*Excerpts from the bibliography sent to NOAA for the SLO County Marine Sanctuary Proposal. PG&E WAS GIVEN A COPY IN 1990.
Sincerely,
Karl Kempton, Former Energy Planner for San Luis Obispo County and lead author of "Proposed Central Coast National Marine Sanctuary, 1990"
Carol Georgi
Mailing address: P O Box 13222, San Luis Obispo, CA 93406-3222
Addendum
Continuation of section 4:
Detailed Overview of Marine Environment
Note: We include the topic of threats to these areas to underscore that the seismic testing will add to the existing stress unmentioned in the EIR
The following are complete or partial text excerpts from a series of articles for a proposed national marine sanctuary or national ocean monument published in the Slo Coast Journal.
A) April 2010
B) August 2010
C) September 2010
D) October 2010
E) November 2010
F) May 2011
G) May 2011
H) June 2011
I) July 2011
J) January 2012
*– BIBLIOGRAPHY
The following are excerpts from the bibliography sent to NOAA for he SLO County Marine Sanctuary Proposal. PG&E WAS GIVEN A COPY IN 1990.
Also missing from the EIR bibliography are works by Craig Nicholson of UCSB, an expert in local seismic activity.
