False Assumptions in PG&E's Proposed Seismic Surveys
by Carol Georgi and Karl Kempton
Former Energy Planner for San Luis Obispo County
Lead Author of Proposed Central Coast National Marine Sanctuary, 1990"
Preface
Our October 2012 article, PG&E's Proposed Acoustic Seismic Testing Off the California's Central Coast Should Be Denied, is useful in understanding PG&E's proposed seismic survey.
Announcements
Upcoming Events from COAST
October 30 – SLO County Board of Supervisors Meeting
November 11 – S.O.S. Save Our Seas Music Festival
Stop the Diablo Canyon Seismic Testing Facebook Family
November 9-10 – Surfing for Hope Benefit Dinner, Surfing Contest, and Health Fair
November 14 – Coastal Commission Meeting
Hearing on PG&E Seismic Testing Coastal Development Permit Application
California Coastal Commission / Seismic Survey
Comments due by November 11, 2012
Cassidy Teufel
California Coastal Commission
Energy, Ocean Resources and Federal Consistency Division
45 Fremont St., Suite 2000
San Francisco, CA 94105
FAX – (415) 904-5400
Email – PGE Seismic
Introduction
While marine animals have many natural defenses, they are powerless against human threats of pollution, ocean warming, over-industrialization, and acoustic high intensity seismic testing (HESS). A marine sanctuary is one of the few locations for sustainable fishing, and for marine mammal protection. However, the area between two sanctuaries has little protection.
PG&E is planning to use high intensity acoustic blasting between the Channel Islands and the Monterey Bay Sanctuaries off the central California coast. Both sanctuaries are concerned about the decibel level of the pressure waves as they enter the sanctuaries. Furthermore, the California Coastal National Monument with its specific regulatory requirements managed by the Bureau of Land Management is being ignored.
Decibels are logarithmic, meaning every 10dB increase translates into roughly ten times more intensity. Eighteen air guns towed by a boat following a grid pattern will produce repeated acoustic pressure waves that will travel hundreds of miles. The air guns will be firing up to 260 decibels (dB) every 15 seconds day and night for 12 days in Estero Bay in 2012. Also, more seismic surveys are planned for 2013.
Decibels are logarithmic, meaning every 10dB increase translates into roughly ten times more intensity.
We are concerned PG&E's proposal for permits to perform acoustic HESS and PG&E's Final Environmental Impact Report (EIR) for the proposed Central Coast seismic imaging project that was certified by the California State Lands Commission (CSLC) on August 20, 2012 are based on false assumptions.
False Assumptions
False - PG&E is mandated to perform a seismic survey with high intensity acoustic seismic blasting.
California law AB 1632 requires PG&E to study existing studies. The CSLC directs PG&E to perform seismic studies, but does not require acoustic high intensity sonic blasting.
The CSLC approved PG&E's request to charge their rate-payers $64 million dollars to pay for the seismic studies. Since this financial approval, PG&E and others have been in a rush to complete the surveys. The money is a temptation for cash-strapped agencies and others to make decisions that will have countless unintended consequences.
The proposal to conduct high intensity acoustic sonic seismic studies of the ocean floor along the Central Coast is PG&E's response to recommendations made by the 2008 California Energy Commission Report, "An assessment of California's Nuclear Power Plants: AB 1632 Committee Report."
The California Energy Commission (CEC) was directed by AB 1632 "to assess the vulnerability of the state's operating nuclear power plants." The bill did not require the kind of seismic studies that PG&E is proposing. In 2009, the CEC and the California Public Utilities Commission directed PG&E to complete the three-dimensional geophysical studies recommended by the CEC.
PG&E is not mandated to use high energy seismic testing. Alternative technologies need to be considered, and perhaps save rate-payers money.
False – There are no alternative technologies to use for a seismic survey.
"Alternative Technologies to Seismic Airgun Surveys…," edited by Dr. Weilgart, professor at Dalhousie University discusses many alternative technologies. Lindy Weilgart, PH.D. - Areas of expertise include cetacean, effects of military sonar/seismic on whales, marine noise pollution, vocal behavior, and whales.
False – Statistical comparisons of 'take' between many studies and EIRs are statistically comparable
"Take" is defined by the Marine Mammal Protection Act of 1972 (MMPA) as "harass, hunt, capture, kill or collect, or attempt to harass, hunt, capture, kill or collect."
Karl Kempton earned a minor in mathematics with a statistical emphasis and was a former paid statistician. He will address perhaps the most glaring false assumption, in his opinion.
This glaring false assumption is the use of various sonic research papers and conclusions based upon these studies to forecast the numbers of 'take' for various mentioned and unmentioned marine life species, especially mammals. The sited studies, statistically speaking, are not in the same 'statistical universe' as the proposed seismic imaging project.
PG&E's proposed intensities and durations of the sonic waves exponentially far exceed any sited study or studies; the proposed intensities and durations of the sonic waves are unprecedented in scope compared to any referenced study. Thus, the predictive model is useless other than a significantly understated guess.
Moreover, PG&E's EIR ignored the conflict between the federal government's assumed lower standards or assumptions of sonic impacts to marine life, especially mammals, and those of the California Coastal Commission's Report on Acoustic Impacts on Marine Mammals that are stated significantly higher. (See: Coastal CA / Energy / Comments)
The differences between these two standards are of statistical significance.
There are major concerns regarding the documents prepared by NSF and the EA prepared by Padre Associates, Inc. Both contradict the high levels of 'take' forecasted by both the DEIR and EIR of PG&E by stating that there will not be significant impact on the environment.
False – PG&E's (HESS) will have insignificant impacts on people – Human Mammals
Humans who recreate in the ocean during testing periods will be in danger of receiving internal tissue damage from high intensity decibel shock pressure waves.
PG&E plans to create a 160dB received sonic wave safety radius around the blasting area, including coming to the shoreline where people are recreating in the ocean. The US Navy determined a man's threshold is 145 dB before internal tissue damage occurs. (See: Navy Study)
Brad Snook, Chair San Luis Obispo Chapter of the Surfrider Foundation, gives complete information on the recreational impacts in his letter to the California Coastal Commission.
False – PG&E will manage both the Low Energy Seismic Survey (LESS) and the HESS With Integrity and Credibility
According to PG&E, they began the first phase of the LESS in 2010, and completed the second portion in 2011. During the week of August 20, 2012, PG&E resumed LESS research work off portions of California's Central Coast.
PG&E has not announced more LESS research work. However, according to Steve McGrath, Harbor Manager of Port San Luis, The M/V Chinook is due to begin operation from November 5-16th, daylight hours only. Equipment used is multi-beam and side scan sonar with a length of tow at approximately 500'. The survey area on the permit is Estero Bay, by Toro Creek. This is sea floor mapping sonar not penetrating sound.
Recent events with PG&E's low intensity seismic survey (LESS) lead us to believe PGE is lacking credibility and accountability. There may be many violations with their contractor whose survey vessels were not properly permitted, mitigated, or monitored. Therefore, we are concerned about PG&E's attempt to perform a high intensity seismic survey (HESS).
Several fishermen have reported difficulties with the PG&E's implementation of the LESS. Many believe their interests were overlooked when PG&E hired Fugro as their contractor of the LESS.
Brian Stacy, Vice President Port San Luis Commercial Fishermen's Association, reported the fishermen problems compounded when they learned CSLC granted Fugro a 1984 geophysical survey general permit.
The companion Negative Declaration, ND 358 was not updated to include today's regulations and expectations, such as protection of the Marine Protected Areas.
There was no mitigation for lost catch meetings, failure to enforce mitigation measures, 50% loss catch rates, failure to address Marine Protected Areas no take regulations, no compensation issues, and more.
Stacy said their main concern for the marine environment and for the financial survival of their fishing businesses is that no baseline data was collected before the LESS began. Since the fish catch rates went down 50% and since many birds, mammals, and fish disappeared either by their death or by leaving the area, we cannot know the abundance and diversity of marine life before the LESS began.
False – The local fishermen will not lose significant catch.
The Morro Bay and San Luis Harbor fishermen have worked for decades to create sustainable, locally "branded" fishing. They now stand to lose their livelihoods. The EIR states that fishing will end for an unknown length of time. Loss of fish stocks and the marine web-of-life is especially significant for the Marine Protected Areas within the seismic testing zone.
"The process for compensation of commercial fishermen remains vague and does not apparently extend to long-term impacts nor to cascading effects on onshore fishing-dependent businesses," commented Eric Greening, environmentalist and political watchdog of SLO County.
We have learned the fishermen's catch rate went down 50% during and after the LESS. During HESS many sea life, especially fish will probably die and become organic flotsam (remains) that could possible clog the cooling water intake of Diablo Canyon Nuclear Power Plant and cause it to shut down.
False – No mammals will die.
"They can't protect themselves" is an impressive video of armored ocean creatures created by sculptors to emphasize the vulnerability of marine mammals.
See: Surfrider Foundation "They Can't Protect Themselves"
The animals of the ocean need protection from human threats. So to visualize this growing problem, Surfrider enlisted the help of two amazing sculptors and had life-size suits of armor built for a dolphin, clown fish, sea otter and a crane. The exhibit is currently at the Aquarium at the Pacific in Long Beach, CA.
PG&E's EIR Does Not Explain How Air Guns Can Injure and Kill Mammals
Sonic blasting with air guns creates acoustic shock waves that travel underwater in the ocean. When the wave reaches your skin, it would pass through you. Little of its power would be reflected because your body's density is similar to that of the water.
The shock wave would hit the air-filled pockets of your body and instantly compress the gases there, possibly resulting in blocked blood vessels, ruptured lungs, torn internal tissues and even brain hemorrhaging. Waves hitting the surface of the water or the bottom ground would bounce back, inflicting even more damage. (See: How Stuff Works - Anatomy of an Underwater Explosion)
Please read "Underwater Blast Injuries" by Dr. P. G. Landsberg MD for more details of injury and death caused by acoustic shock waves.
PG&E must consider public safety and more recent research showing 160 dB are not safe for most marine mammals.
PG&E's proposed seismic survey for box 4 uses arrays of 18 air guns pulled behind a boat following a grid pattern blasting 250 dB every 15 seconds around the clock for 12 days.
Four impacts a minute, 40 impacts in 10 minutes, 240 impacts in 1 hour, 5760 impacts in 1 day (24 hours), and 69,120 in 12 days would mean sea otters could not dive to gather their food.
Map by Karl Kempton
The map for Track 4 (above) is based upon the "Draft Environmental Assessment of Marine Geophysical Surveys by the R/V Marcus G. Langseth for the Central Coastal California Seismic Imaging Project." It was submitted to the National Science Foundation, Division of Ocean Sciences by Pacific Gas and Electric Company in May 2012. The template map is found in the PDF copy on page 206 in Appendix B, Marine Mammal Densities and Figures for Survey Boxes 1-4." The title of their map is "Figure B-4. Box 4 Calculated Safety Zone Based on the 160dB Distance."
The red zone is the area within which the ship will be dragging its array of sonic guns blasting between 260dB to 240dB every 15 seconds 24 hours a day for 12 days. This makes for the calculated total of 69,120 repeated blasts. The yellow hash line on the perimeter of the map is THEIR estimated radius from the maximum of 260-240 dB dampens down to 16dB.
Why is the range between 260dB to 240dB? The submitted documents and various expert testimonies on behalf of PG&E are inconsistent. They have stated 260dB, 250dB and 240dB as the maximum levels.
To call 160 decibels the safety limit belies the science of damage caused between 159 and 120 decibels. Further, note that 160dB radius enters the Morro Bay National Estuary.
False - Fish and other marine life will survive because they will leave the blasting area, and we will provide a safety limit radius.
This statement implies staying in the blast area will result in death, and ignores the shellfish, such as abalone and other marine life that cannot move quickly and leave. Thus, the marine life, including fish eggs, larvae, plankton, etc. will be destroyed within the blasting area.
The most glaring omission is that neither a general nor detailed description of the marine web of life can be found. We note a total lack of narrative and study related to the complex web of life. The sonic blasts will greatly impact and in many cases either scatter or destroy populations critical to the web of life — or food chain — thereby causing a much greater and significant number of injured and overall damage than predicted by mere sonic waves. The most glaring contradiction is that the only species of concern are threatened, endangered and commercial while at the same time admitting, though understating, the impact on the Marine Protected Areas.
Cummings found that harbor porpoises can only withstand up to 120dB and may not be able to get out of the bay inlet. Beluga whales are also are sensitive to more than 120dB.
Jim Cummings, Executive Director, The Acoustic Ecology Institute, Santa Fe, New Mexico, US. E-mail Web: AcousticEcology.org
The January-February 2010 MPA News Article
"The 160-dB "safe" criterion noted in the article and widely used in mitigation plans likely represents roughly the sound level at which half the population will be expected to change its behavior in noticeable ways. Unfortunately, the correlation between sound level and behavioral disruption is not at all linear. Many individuals (and some species, particularly harbor porpoises and beluga whales) respond with aversion or foraging disruptions at much lower levels, down to 120dB. There will always be a subset of a population that is more sensitive to noise."
Lindy Weilgart, Research Associate, Department of Biology, Dalhousie University, Halifax, Nova Scotia, Canada. E-mail: Lindy.
The November-December 2009 MPA News article (MPA News 11:3) on seismic surveys and MPAs resulted in a letter from Lindy Weilgart, PhD stating that "whale and fish disturbance is well documented at receive levels of 130 decibels (dB) and below—in contrast to the 160-dB threshold used at Endeavour, which is 1,000 times louder."
"It is time to seriously research and promote more benign air gun alternatives such as, perhaps, controlled sources, passive seismic [the detection of natural low-frequency earth movements], electromagnetic surveys, etc. - especially in sensitive habitats."
False – Sea Otters will be fine because their ears are mostly out of the water.
Southern Sea Otter - PG&E's request for Incidental Harassment Authorization (IHA) and permit for incidental take of Sea Otters
We are seriously concerned for the welfare of Southern Sea Otters during PG&E's proposed Central Coastal California Seismic Imaging Project.
We find the Sea otter study paid for by PG&E unacceptable with its treatment of sea otters because they are not being protected. Evidently, the researchers will monitor how the sea otters may move away or experience injury or stress while trying to dive for food in the testing area.
We are surprised and seriously concerned that 60 sea otters have already been captured, tested, tagged, surgically implanted with two devices, and returned to the testing area for a dangerous experiment: "How they are going to react is the million-dollar question," said Tim Tinker, lead researcher for the tagging project with the U.S. Geological Survey. Read full article by David Sneed.
A 2005 permit, #MA672624-16 USFWS, was used for this recent harassment of 60 sea otters. This is a general permit reauthorized from 2005 for Sea Otter research. We do not understand how this permit can be used for this specific project. Does this permit authorize the large cell-phone-size surgical implants? Watch implanting procedure in this KSBY TV video.
For us, this is an ongoing illustration of problems with the various documentation and testimony for and by PG&E. They state as fact the number of sea otter "take," but then fund research to find out what actually will occur in real time.
We find the CA State Lands Commission response to the welfare of the Southern Sea Otters unacceptable, and as written, will put about 702 (25% of state's total) of the Southern Sea Otters in jeopardy from the proposed seismic tests, EIR page 4.4-23 states 702 sea otters in project area.
Sea otters have been protected by law since 1911 and are protected as a threatened species under the 1972 Endangered Species Act. There is a small population of sea otters along the coast of central California.
If the sea otters are to remain within the testing area, the question is: What intensity (decibels – dB) of seismic testing can sea otters tolerate when diving for food.
We find the following statement unacceptable and lacking knowledge and concern of sea otters diet and behavior.
"The NMSF Level A threshold for cetaceans (180dB) was used as the Level B threshold for sea otters. Because sea otters have the ability to avoid immersion of their heads and ears, this Level A noise level was considered to be appropriate for assessing the extent of disturbance (Level B harassment) to Southern sea otters due to noise."
The above response assumes sea otters can tolerate the 180 dB level because that is what they expect cetaceans to tolerate. Sea otters are not cetaceans, and their level of decibel tolerance is probably closer to that of humans when diving, about 140 dB or less.
We are concerned that PG&E does not fully understand the impacts of acoustic pressure waves created by 18 air guns hitting mammals every 15 seconds day and night for 12 days. All parts of a mammal's body will receive internal tissue damage, especially the torso and head, damage is not restricted to loss of hearing.
One only needs to learn about the sea otters' diet and behavior to understand that leaving them within the high seismic testing zone will result in their death. Death will occur from the 250dB sonic blasts every 15 seconds, 24-hours a day for 12 days. Or death will occur from hyperthermia or starvation because of behavioral changes caused by the blasting.
Since the Southern Sea Otter's common habitat is within kelp forests. It is imperative to protect the kelp forests. We are also concerned about the female sea otters, many of which will be pregnant in December. Pregnant sea otters and pups cannot tolerate high intensity seismic pressure waves hitting them every 15 seconds day and night for 12 days.
According to the Central Coastal CA Seismic Imaging Project EA # 3.6.4.1 Southern Sea Otter: Sea otters are most common in and around kelp beds and open water areas support substantially fewer adults. Kelp habitat provides territories and home range areas for male and females and sea otters will regularly be found in the same area over an extended period. Open water areas can and do have large numbers of otters on a regular basis, but the distributions can shift. It is believed that some of the highest densities continue to be found in open water habitat, such as Estero Bay, Monterey, and offshore of Pismo Beach (Figure 3-11) (M. Harris, pers. comm., 2011). (See PGE NSF (Coastal) EA)
Death by Seismic Testing
Sea otters are not comparable to whales in determining the level of seismic blasts they can withstand. They should be exposed to less intensity than would be recommended for humans.
Death by Hyperthermia
Sea otters need to eat about 25% of the weight in food each day in order to retain their body temperature as they have no blubber. Not being able to dive to get their food due to intense seismic blasting will result in them not eating enough to maintain their body temperature.
Death by Starvation
Sea otters spend much of their lives in the water and can dive up to 330 feet when foraging for food. The reason they dive is that the food is on the bottom of the ocean. Therefore, the intensity of the seismic blasts will determine if the sea otters can tolerate diving for their food.
Sea otters eat many kinds of invertebrates, including clams, snails, sea stars, sea urchins, crabs, squid, octopuses and abalone. This food lies at the bottom of the ocean, where they also pick up a rock. They carry the food and the rock up to the surface. Then they use the rock or other objects to pry and to hammer them open.
We are seriously concerned that the monitoring plans allow the high intensity seismic decibels to be increased if the sea otters appear undisturbed.
We are seriously concerned about the lack of post-activity monitoring plans. Tissue damage to mammals may not be noticed immediately, and the bodies may wash ashore during the weeks following the seismic testing. For example, during and in the weeks following the low energy seismic testing, many birds died, and many mammal's bodies washed ashore — -dolphins, seals, sea otters. However, no monitoring was in place to collect data.
False - PG&E's proposed acoustic blasting will not harm marine sanctuary resources.
The testing area has been approved eligible for marine sanctuary designation since 1990, and sits between the Channel Islands Sanctuary and the Monterey Bay Sanctuary. PG&E states in their EIR, "Sound will travel hundreds of miles and still be 120dB as far away as 58.95 miles according to PGE report." The damaging acoustic pressure waves will travel into both National Marine Sanctuaries and be 120dB or stronger. (See: The Monterey Bay National Marine Sanctuary comments to the draft EIR)
Conclusion
Not rushing forward with these high intensity seismic tests will give the peer group and PG&E time to review and evaluate the land tests and the low level ocean tests. After this review, scientists can learn what alternative technology can be used to protect our marine life ocean resources, especially sea otters.
Our ocean life and marine food supply are too valuable to recklessly destroy. The Precautionary Principle MUST the guide for decisions that are made regarding threats to marine life.
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Maps (by Karl Kempton, former Energy Planner of San Luis Obispo County) show combined effect of constant blasting within the entire area of PG&E's proposed seismic survey
Impact of One blast
Impact of Four Blasts in One Minute
Impact of 40 Blasts in 10 Minutes
