Ten whale groups slam Atlantic OSW

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Ten whale protection groups, including some prestigious names, filed lengthy and highly critical comments on the Bureau of Ocean Energy Management’s “DRAFT BOEM and NOAA Fisheries North Atlantic Right Whale and Offshore Wind Strategy, October 2022”. Below are some excerpts to give the flavor of their anger.

Note that NARW is the severely endangered North American Right Whale, the shrinking population of which migrate up and down the East Coast every year. The migration route passes or crosses the numerous proposed offshore wind sites, with potentially thousands of huge wind turbines in their path. Hence the deep concern.

Here are the whale protection groups:

American Cetacean Society

(Cetaceans are whales, porpoises and dolphins)

Save the Whales

(The original defender)

Whales of Guerrero

The Great Whale Conservancy

Gotham Whales

Ocean Conservation Society

Coastal Research and Education Society of Long Island, Inc.

Ocean Conservation Research

Sea Life Conservation

Oceanic Preservation Society

Their first concern is that the offshore wind site leasing itself should have gone through a rigorous environmental impact assessment, before any work was done on the numerous lease sites. Likewise the noisy acoustic site characterization surveys. Here is part of their detailed issue analysis:

“BOEM, under Biden-Harris Administration, continues to decline to make an Environmental Impact Statement (EIS) prior to lease sale of ocean areas, even knowing that such lease sales, with 100% certainty, will result in sea floor exploration/SAP activities requiring ensonification, and knowing that based on the sound frequency at which NARW communicate, adverse effects on the remaining NARW population of such sound-producing site-characterization activities are highly likely. Likewise, BOEM, continues to issue determinations of “no significant impact” in Environmental Assessments of lease area exploratory activities (“site characterization”) by the lessee-developers. There is reason to find that such determinations are inappropriate, and that a full review of such activity is warranted. There is reason for grave concern.”

“Even forgetting about the environmental impact of pile driving, and the effects of turbine operation (impacts from noise, sea strata mixing, weather changes), given the ample evidence that there are significant harmful effects to marine life of sea-floor characterization activity (because this activity entails ensonification of vast areas of ocean floor. This is typical of SAP/lease area characterizations by developers of the lease site), and given that the sea floor of these lease areas will be characterized if a lease sale goes through, then— under most circumstances—a finding of no significant impact of such ensonification activities will not be a reasonable one and a full review should be performed resulting in an Environmental Impact Statement (EIS) of these lease site characterization activities.”

They also point out that the so-called Draft Strategy includes little or no actual strategy, saying this among other things:


A NARW Strategy Document should contain actual strategy. The purpose of actually stating strategy in a Draft Strategy document is so that BOEM and NOAA can get public feedback and improve on the strategy. The Draft NARW Strategy Document is short on actual strategy, but long on statements that BOEM and NOAA will work together, on more highlights of the need to develop a strategy to address threats, plans for outreach to others, categorization of what tools will be used in the future to develop a strategy, announcements that it will develop a strategy, announcements that it will develop decision-support tools, announcements that the agencies will be proactive in presenting the strategy once it is formed, announcements that it will assess our current understanding of threats, and declaration of intention to develop a list of preliminary measures, and listing of preliminary measures that it will consider (read could require) for any individual project.

Here is their specific request:

“This is doublespeak and filler-talk. We respectfully request BOEM reissue the Draft with a actual strategy.”

They also get into deadly noise pollution in considerable detail. For example saying this:

“The Draft EA for the Empire Wind, for example, shows the brand and model of Sparkers and Seismic Air guns (so-called bubble” guns) that are representative of those expected to be used. This equipment will emit sounds of the same sound frequencies as the calls of the NARW, which anthropogenic sounds are received by the NARW louder (188dB and 192dB respectively) than are the natural calls of the NARW, and thus are reasonably expected to “mask” them, or in common terms, drown them out. Right whales are highly dependent upon sound to maintain contact; They emit contact calls to communicate with conspecifics to keep aware of each other’s locations. Additionally mothers and young calves must maintain close proximity in order for the calf to nurse and for the mother being able to protect her calf by placing herself between her calf and predators, and NARW use contact calls to do this.”

“It is important to understand that the decibel scale is a logarithmic one. So, as is the case here (example above taken from actual developer’s plans), sound-emissions with a dB level that is 25 to 35 dB higher than the whale’s call has a loudness level of about six to ten times the whale call’s loudness.”

Here is some research to go with their comments. Regarding whale mothers and young calves, it was recently discovered that right whale mothers use unique low volume calls to communicate with their babies, which can be just a few months old on their first migration up the Atlantic coast.

See Acoustic crypsis in communication by North Atlantic right whale mothercalf pairs on the calving grounds”.

Here is the general finding:

“Acoustic crypsis is a behavioral adaptation to reduce detection by eavesdroppers, including predators. This approach towards reducing conspicuousness is beneficial for species that rely primarily on acoustic signals for communication. Acoustic crypsis may be particularly effective in aquatic environments where the potential range for eavesdropping by predators is greater owing to more efficient signal propagation in water than in air. Right whale mothers produced a higher proportion of quieter, lower-amplitude acoustic signals than pregnant or juvenile whales in the same habitat, suggesting that right whales do use acoustic crypsis when calves are the most vulnerable to predation. This finding is consistent with a previous study of humpback whale and Southern right whale mother–calf communication where mothers and their dependent calves produced typical acoustic signals at reduced amplitudes, reducing the potential range for detection.”

Here is the key finding of specialized quiet language:

However, rather than simply producing the normal acoustic repertoire at lower amplitudes, North Atlantic right whale mothers with young calves switch their repertoire usage to predominantly produce very quiet call types that are rarely detected in recordings from other demographic groups of right whales.”

There is a lot in these detailed technical comments and new research findings for BOEM and NOAA to consider. Let’s hope they do.

  • David Wojick

    David Wojick, Ph.D. is an independent analyst working at the intersection of science, technology and policy. For origins see http://www.stemed.info/engineer_tackles_confusion.html For over 100 prior articles for CFACT see http://www.cfact.org/author/david-wojick-ph-d/ Available for confidential research and consulting.

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