PG&E's Proposed Acoustic Seismic Testing
Off the California's Central Coast Should Be Denied
Location of Proposed Seismic Testing
PG&E's proposed acoustic seismic survey is planned to occur in 540 square miles of the ocean area between the Channel Islands National Marine Sanctuary and the Monterey Bay National Marine Sanctuary. Our June 2012 Marine Sanctuary Article detailed information on the "Concerns and Risks of PG&E's Proposed Central Coastal California Seismic Imaging Project."
These two protected sanctuaries and the ocean area between them share many marine species that swim into the seismic testing ocean area to feed. Marine mammals especially feed from the year-round persistent upwelling between Point Conception and Point Sal. This upwelling flows through the submerged five-fingered Arguello Canyon. (See: SLO Coast Journal June 2011)
A large portion of this seismic testing ocean area, including the Santa Lucia Bank, was nominated twice through Congressional legislation for National Marine Sanctuary designation in the early 1990's. (See: May 2011 SLO Coast Journal)
PG&E's Proposed Seismic Zones of 4 Boxes with Boat's Grid Patterns of entire two-year survey.
Testing Zone Box 4 with the Boat's Grid Pattern is Planned to begin November 19, 2012
Testing Zone Box 4 Cumulative Sound from Airguns
Impacts to Marine Web-of-Life and Coastal Economies
PG&E's proposed seismic testing would be catastrophic to local marine life, especially marine mammals, which rely on their sensitive auditory capabilities for communication and navigation. The takings permit for the project – the estimated amount of wildlife that could be killed (Page 4.4-79 of the EIR) includes "One minke whale, two sperm whales, five dwarf sperm whales, 13 humpback whales, 15 blue whales, 25 fin whales, 97 California gray whales, one short-finned pilot whale, three Baird's beaks, seven orcas, eight striped dolphins, eight small beaked whales, 81 Dall's porpoise, 82 long beaked white-sided dolphins, 1,652 bottlenose dolphins, and 1834 short-beaked dolphins, 76 harbor seal, 1,062 California sea lions, 1,485 southern sea otters, untold sea turtles, numerous fish and bird species and larva." (See: SLC CA)
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.
Receiving acoustic blasts at 250 decibels every 15 seconds around the clock for weeks will destroy the marine web-of-life within the survey areas because the decibel level is too intense. The boat will follow a grid pattern within the survey area assuring a "Cleansing" result of all marine life, including marine mammals, crabs, abalone, fish, larvae, eggs, plankton, algae, kelp forests, etc, as we described in our September 2012 SLO Coast Journal Article.
We urge all commissions and agencies to consider how much granting a permit would ask these coastal communities and marine web-of-life to sacrifice in exchange for a few more years of operating an old nuclear power plant located on and near faults.
We question that PG&E's Sonic Seismic Studies are Mandated by California State Laws.
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.
The State Lands Commission (SLC), lead agency on the proposed project, certified the EIR for the project on Aug. 14 and on Aug. 20, 2012, the SLC adopted the Mitigation Monitoring Program, Findings, and Statement of Overriding Considerations.
National Resources Defense Council Calls for Stop to PG&E's Seismic Test, and Urges Coastal Commission to Deny Permit
California Fish and Game Commission Meeting September 24, 2012
The CA Fish and Game Commission (CFGC) met in Sacramento on September 24, 2012 to gather information and discuss the status of PG&E's proposed Central Coast seismic imaging project, PG&E's application for a Scientific Collecting Permit.
The CFGC has regulatory authority to protect natural resources and oversee Marine Protected Areas, including those near Diablo Canyon. However, the Fish and Game Commission does not have authority to manage whales, dolphins or sea otters. Marine mammals are protected under federal authorities.
Internationally and locally, the public is concerned about PG&E's proposed seismic testing. The Commission received over 50 letters and faxes and 44,000 emails before they had to shut down the email account.
Many citizens representing 10,000 residents of Morro Bay and nearby coastal communities in San Luis Obispo County, CA drove six hours to Sacramento to speak three minutes each to the CFGC.
Fred Collins, Tribal Administrator of the Northern Chumash Tribal Council, stated the Chumash Nation has lived in the San Luis Obispo coastal areas for 18,000 years, and they do not give a permit to extract cultural resources important to their nation. He emphasized destruction of submerged Chumash Sacred Sites and Chumash Cultural Resources would violate sections of the United Nations Declaration of the Rights of Indigenous Peoples. (See: The Northern Chumash Tribal Council (NCTC) )
During public comment, representatives from Stop Diablo Canyon Seismic Testing, COAST, National Resources Defense Council, Sierra Club, Ocean Conservancy, Greenpeace, Surfrider Foundation, Sea Shepard, and many others asked the CFGC to deny giving PG&E a permit that would decimate the fishing stocks and marine web-of-life. Some stated PG&E's proposal for the acoustic seismic survey is not mandated.
No decision was made, and CFGC directed its staff to attend the Oct. 10-11 meeting of the CA Coastal Commission to gain further information before considering granting a permit to PG&E.
CFGC President Jim Kellogg of Discovery Bay stated, "It's a Marine Life Protection Area, not a Marine Life Killing Area, and as long as I'm here we're not gonna recommend to the Department (Fish and Game) anything that's kill'n anything that we're trying to protect."
Watch the California Fish and Game Commission September 24, 2012 meeting online to hear the full story.
We are concerned about the damage this seismic testing proposal would have locally and internationally, and we are working with others to prevent unnecessary damage to the marine web-of-life and the local economies.
Local Activist Groups Formed to Stop the Seismic Testing
Two local grass-root groups of concerned citizens have been organized and are actively speaking, writing letters, posting information, planning events, and receiving international attention and support. The local San Luis Obispo Chapter of Surfrider Foundation is working with both groups. SLO Surfrider's presents their 10th annual Cayucos Freefall Art & Music Festival October 20th at the pier. Cayucos in on Estero Bay and Surfrider Freefall will include information tables on seismic testing.
1)Stop the Diablo Canyon Seismic Testing Facebook Family
Founded by Joey Racano of Los Osos on July 13, 2012 with the focus on Saving the Whales from harm caused by sonic blasting. The group has inspired a community to learn about the seismic tests and write letters to stop this harmful testing with high intensity sonic blasts.
*Facebook page is enjoyed my many as it is updated daily with whale inspired poetry and art.
*Several people post important information about whales and seismic testing with sonic blasts.
* Organized the successful letter/email and speaking campaign to the CFGC and to the CCC
2) C.O.A.S.T: Citizens Opposed to Acoustic Seismic Testing
Founded by Mandy Davis and Mark Tognazinni of Morro Bay on September 14, 2012 with the focus on helping the commercial fishermen. Most of the group is from Morro Bay and they are working to stop the seismic tests so the fishermen do not lose their fish stocks.
*Posts information and action items.
*Communicated with the CFGC and organizing for more active participation.
Announcement of October Events in Morro Bay and Cayucos (Estero Bay)
October 6th & 7th –10am-6pm - Morro Bay Harvest Festival
COAST event: Land and Sea rally in Morro Bay during the Harbor Festival
See COAST facebook for details.
October 8 - Calling of the Whales – See the Event Calendar on Facebook
Starting at 3:00pm in the Avila Parking lot: Come meet Mz Blue, the 90' Great Blue Whale provided by Gershon Cohen, from the Great Whale Conservancy, and a Gray Whale dirigible, provided by Farmer's Kites of Morro Bay. Visit the nearby Avila Beach Sea Life Center, and visit our booths!
Then at 6:30pm on Port San Luis Beach, join us in the 1st ever Calling of the Whales!
At sundown, we will gather around a roaring fire on Port San Luis Beach, where a member of the Chumash Tribe will blow the sacred Conch Shell and Call to the Whales of Avila. Greenpeace will unfurl their famous banner and then we will begin the light festival, using flashlights to create a human-powered pinwheel! Facebook Page
Deny Permit for Seismic Blasting or Restore Ecosystem
We ask the commissions to deny or postpone issuing a geophysical survey permit to PG&E for high intensity seismic testing in San Luis Obispo County. Further, we state that if the permit is allowed, then the only acceptable mitigating condition is the restoration of the marine ecosystem damage.
We suggest the mitigating condition of $2.5 million per year for 20 years to provide funds for a basic marine sanctuary for the restoration of sustainable fishing and ecosystem health. For example, Rockfish need to be about 20 years old to reproduce.
This mitigating condition would save the City of Morro Bay and other coastal communities, as well as give back to the ocean. This mitigation is in addition to the settlement PG&E is offering the fishermen for lost catches due to seismic testing. The EIR states that commercial fishing will end for an unknown length of time.
Additional Permits PG&E Needs to Acquire
The agencies besides the Lands Commission are the California State Parks, California Department of Fish and Game, Central Coast Regional Water Quality Control Board, National Science Foundation, National Marine Fisheries Service, United States Fish and Wildlife Service, United States Army Corps of Engineers, United States Coast Guard, and San Luis Obispo Air Pollution Control District.
Please see Jack McCurdy's article, "Seismic Studies Likely To Be Delayed," SLO Coast Journal, September 2012 for the complete list of needed permits.
The California Coastal Commission - The California Coastal Commission (CCC) will consider PG&E's application for a coastal development permit at their November 14-16, 2012 in Santa Monica, California. The CCC has posted the background materials to PG&E's Offshore Seismic Survey. Meeting Location: Santa Monica Civic Auditorium – East Wing, 1855 Main Street, Santa Monica, CA 90401
PG&E revised its project to only include the survey of "Box 4" in Estero Bay. A detailed description of this new proposal is on the CCC website as a link from their agenda: Coastal California / Seismic Survey .
a. Application No. E-12-005 and CC-027-12 (Pacific Gas & Electric Co., San Luis Obispo Co.) Application of PG&E to conduct a high energy three-dimensional geophysical survey employing use of air guns, hydrophones, and seafloor geophones in state and federal waters offshore San Luis Obispo County. (CT-SF)
We encourage you to write letters and mail or FAX to the CCC stating your concerns.
California Coastal Commission
Central Coast District Office
Dan Carl, Deputy Director
725 Front Street, Suite 300
Santa Cruz, CA 95060-4508
FAX (831) 427-4877
The National Marine Fisheries Service (NMSF) and the National Oceanic and Atmospheric Administration (NOAA), Department of Commerce
Federal Register / Takes of Marine Mammals Incidental to Specified Activities
Posted Notice of Action: Incidental Harassment Authorization; request for comments in the Federal Register, Vol. 77, No. 182.
Takes of Marine Mammals incidental to Specified Activities; Marine Geophysical survey of the Central Coast of CA, November to December, 2012.
Comments and information must be received no later than October 15, 2012.
Comments on the application should be addressed to:
P. Michael Payne, Chief, Permits and Conservation Division, Office of Protected Resources, National Marine Fisheries Service, 1315 East-West Highway, Silver Spring, MD 20910
Email comments including attachments must not exceed a 10-megabyte file size.
No announcement of a public meeting at this time.
DCNPP Seismic Issues – Overview by Karl Kempton
The land mass west of the San Andreas Fault, north from Tomales Bay and south to the tip of Baja, is on a tectonic trajectory to form an archipelago off North America. Rifting is occurring up the Sea of Cortez into California pushing Baja westward. Baja's pressure causes the Western Transverse Block to our immediate south to rotate. The rotation to the current moment has been over 90 degrees since the process began. This rotation places pressure on our land mass, that in part causes of the uplift of the Irish Hills and the deformation of the seabed off our coast. The cracks in the seabed, the Hosgri, Santa Lucia and other faults, are a result of these and other tectonic forces which are tremendous in nature. Only recently has this macro picture begun to be understood. Cataclysmic ruptures are in our near and distant future.
The Diablo Canyon Nuclear Power Plant would not be permitted on its present site today. It may not have been permitted had PG&E not covered up and down played an earthquake fault upon which they built the power plant, i.e. within 500 feet and perhaps running under one of the nuclear reactor units.
Carl Neiburger reported the 14-year cover-up by PG&E in the SLO Tribune on November 5, 1981. "PG&E found evidence of an earthquake fault within 500 feet of the Diablo Canyon Nuclear Power Plant in 1967, but chose not to pursue it to avoid ‘additional speculation and possibly delay the project.'"
The "fault" referenced in the article is the fault Dr. Hamilton refers to today as the "Diablo Cove Fault." It had never been given a formal name until a couple of years ago when Dr. Hamilton submitted his first treatise (and draft) of his paper on this subject to the California Energy Commission.
We question that the Diablo Cove Fault is not included in the fault lines printed on the EIR map. This is the fault line that remains undiscussed. Does the fault extend under Unit One nuclear Reactor and out to sea connecting, perhaps, with the Shoreline fault discovered by the USGS in 2008?
Final Environmental IMpact Report (EIR)
Include Dr. Hamilton's scope
We ask for land seismic surveys and low level ocean seismic surveys to be evaluated, and Dr. Hamiliton's scope to be included before rushing to destroy the precious marine life within these waters and financially impacting coastal communities. (As printed in the September, 2012 Slo Coast Journal.)
In their June 4, 2012 letter (printed at end of letter), The Alliance for Nuclear Responsibility (A4NR) asked the CA State Lands Commission to require PG&E to specifically delineate the changes in its offshore and onshore study plans necessary to gather data to fully assess the "missed fault" recommendations of Dr. Douglas Hamilton, as graphically mapped in the DEIR comment submitted by geologist Erik Layman. (Central Coastal California Seismic Imaging Project)
Dr. Hamilton was part of PG&E's Diablo geosciences team from 1971 to 1988.
Rochelle Becker, Executive Director of A4NR states that the CA Public Utilities Commission (CPUC) Judge proposed decision in the Diablo seismic funding case stated that they expect PG&E to include Dr. Hamilton's scope and that is what ratepayers expect for their multimillion dollar expenditure.
Dr. Douglas Hamilton's point in his testimony before the CPUC, February 10, 2012: " . . . nothing in the planned additional surveys, both onshore and offshore, offers any prospect for any result beyond marginal improvement to what is already known."
Andrew Christie, Director of the Santa Lucia Sierra Club states: "PG&E says they will incorporate the additional onshore areas he pointed out they had ignored in their initial survey design; they have not said they are deleting offshore areas he pointed out as already sufficiently studied, or sought his input on which areas those are, beyond the now-deleted Cambria Stepover."
The U.S. Geological Survey Seismologists are not expecting anything strikingly new from the $64 million PG&E Central Coast Seismic Test as it is not likely to reveal critical new data such as fault length, rate of slippage or past frequency of eruptions.
PG&E and some U.S. Geological survey geologists differ over the placement and length of the fault lines near DCNPP. PG&E may be misrepresenting the Shoreline fault as the Fault lines map shows.
"One USGS scenario shows the Hosgri Fault extending 250 miles from Point Conception to Bolinas, just beyond San Francisco, 145 miles longer than its officially published length of 105 miles. The longer the length of the Hosgri, according to Mr. Johnson, the more likely it could connect with other faults to the north of the plant to produce "close to an 8.0" earthquake. Diablo Canyon was constructed to withstand ground-shaking from a 7.5 earthquake on the Hosgri, three miles off shore. This scenario might elevate concerns." (See: Rock of the Coast)
PG&E's Draft EIR Map shows their assumption/error that the Hosgri fault is 105 miles long, compared to USGS scenario of it being 250 miles long. These differences suggest PG&E may be underrepresenting the faults near DCNPP.
Local communities reflect on Fukushima when required to orchestrate an emergency evacuation plan during and after the worse case earthquake.
We question why DCNPP and the onsite storage of nuclear waste have not been decommissioned and/or relocated.
Concluding Background and Additional Information
Marine Life Issues
"Proposed Central Coast National Marine Sanctuary, 1990"
In the early 1990's, the nearshore and offshore waters from Point Sal to Mill Creek were nominated twice in Congressional bills for Marine Sanctuary status due to the international and national significance of bio diversity and density. This ocean area is where the high intensity seismic testing is proposed to occur.
In the first decade of this century, The Channel Islands and Monterey Bay National Marines Sanctuaries studied the unprotected waters between Point Conception and Santa Rosa Creek. Both sanctuaries have published maps and plans as a result of those studies to expand to protect these waters.
See studies:
1) A Biogeographic Assessment of the Channel Islands National Marine Sanctuary, "A Review of Boundary Expansion Concepts for NOAA'S National Marine Sanctuary Program," November 2005
2)
A Biogeographic Assessment off North/Central California: In Support of the National Marine Sanctuaries of Cordell Bank, Gulf of the Farallones and Monterey Bay, "Phase II Environmental Setting and Update to Marine Birds and Mammals," October 2007
West Coast Only Persistent Upwelling --
The oceanographic features of the Santa Lucia Bank, a cetaceous uplift block to within 400 meters of the surface north of Arguello Canyon, the five-fingered Arguello Canyon, running NE-SW to a depth of 3000 meters, the Channel Islands, the Southern California Bite, and a meeting place of various currents all contribute to the only persistent upwelling along the west coast located between Points Conception and Sal.
The September 2010 article of the SLO Coast Journal "Core Area One of the Proposed Marine Sanctuary Expansion - Santa Lucia Bank, Santa Lucia Escarpment, Arguello Canyon and the Persistent Upwelling between Point Conception and Point Sal"
Because of the nutrient-richness of the upwelling waters the area contains a vast array of marine life: a benthic (deep water) community of world-wide significance, simultaneous gathering of 13 whale and porpoise species, and large numbers of birds and fish during the Autumn. The upwelling feeds the entire web of life along the eastern rim of the Pacific Basin including two National Marine Sanctuaries to its South (Channel Islands) and North (Monterey Bay).
The entrained nutrients of this upwelling are the foundational food for the phytoplankton that in turn forms the basis of the web of life for the area and two national marine sanctuaries to its north and south. The phytoplankton richness maintains the internationally and nationally significant bio density and diversity of an area that two marine sanctuaries have called for sanctuary designation through expansion in their research documents and proposals.
This area temporally hosts many seasonal migrating species including the endangered brown pelican and California Grey Whale. The former's pre-wintering rookery population is densest along the shoreline of San Luis Obispo County. Many brown pelicans are in this are in November. The latter population begins its southern bound migration from the Arctic in the late Autumn; its first migrants are known to appear in late October or early November.
Of special note: some commercial businesses use sound waves to kill algae in a cleaning process, and state: The complex pattern of ultrasonic vibrations through the water causes the algae vacuole cell wall to resonate and break,
much like a glass breaking from a high pitched sound. The broken vacuole wall eliminates its ability to grow and reproduce. (See: Spartan Water Treatment)
We question: what will constant bombardment to all forms of algae from single cell to complex kelp do to the food chain? What will it do to single cell plankton and animal life, all of which form the foundation for the area's and the national marine sanctuaries to the south and north?
We are concerned that the marine web-of-life is at risk of surviving. The high intensity seismic testing at 250 decibels is expected to "cleanse" the close-proximity project area of all life.
Death and harm from sound waves occur because sound is a pressure wave. This is why you can feel your body vibrate during loud, low sounds (such as those felt during a concert). Intense waves can rip ear, lung, and other vibrating tissues. They also cause internal bleeding.
To understand the impact of the sonic blasts, look at the numbers as they add up:
One blast every 15 seconds
Four blasts per minute
Two Hundred and Forty Blasts per Hour
5,760 blasts per day
40,320 blasts per week
172,800 blasts per 30-day month
PG&E's sonic seismic studies will violate many existing International, Federal, State, and Local Laws, as well as, Regulatory Requirements and Plans listed in the 4.0 Existing Environment and Environmental Impact Analysis of The Central Coastal California Seismic Imaging Project.
Table 4.0-1 Major International and Federal Laws, Regulatory Requirements, and Plans
Of the many, 30 are listed here:
Monterey Bay National Marine Sanctuary
CA Coastal Act
Coastal Zone Management Act
CA Fish and Game Code
CA Sea Otter Game Refuge
CA Marine Protected Areas
CA Coastal Monument
CA State Parks
Nipomo Dunes National Wildlife Refuge
Estuaries and Natural Preserves
The Endangered Species Act
Marine Mammal Protection Act
Magnuson Stevens Fishery Conservation Management Act
Bald and Golden Eagle Protection Act
Migratory Bird Treaty Act
National Marine Sanctuary Act
Executive Order #13112 to prevent Invasive Species
Executive Order #13158 Marine Protected Areas
Rockfish Conservation Areas
Clean Water Act
California Ocean Plan
Clean Air Act
National Historic Preservation Act
Archaeological and Historic Preservation Act of 1974
Archaeological Resources Protection Act of 1979
Rivers and Harbors Act
Coastal Zone Management Act
California Species Preservation Act of 1970
California Endangered Species Act of 1984
California Marine Life Protection Act
Banner Image of Otter & Pup by Cleve Nash |
