Despite public proclamations of innocence, it turns out BOEM and NOAA clearly acknowledge the deadly threat of offshore wind development to marine mammals. Not surprisingly they do it in documents that are subject to judicial review, lest they be caught fibbing.
Of course these admissions are well hidden, buried in the depths of thousand page documents, but they are there to be found. These are the Draft Environmental Impact Statements (DEIS) that precede each offshore wind project. They are jointly prepared by BOEM and NOAA.
The key is that the overall project EIS includes the EIS for NOAA’s harassment authorizations for the construction of that project. In fact you can find this language by searching the DEIS for the word “harassment”. I am told that this is standard language which varies little from project to project.
The standard language says just what we have been saying! Harassment is likely to lead to dangerous behavior, including increased likelihood of deadly ship strikes and entanglements. It also says, as we have, that having multiple projects increases these risks.
Here is a good example of admitting that harassment can cause harm. I could not have said it better.
“It is possible that pile driving could displace animals into areas with lower habitat quality or higher risk of vessel collision or fisheries interaction. Multiple construction activities within the same calendar year could potentially affect migration, foraging, calving, and individual fitness. The magnitude of impacts would depend upon the locations, duration, and timing of concurrent construction. Such impacts could be long term, of high intensity, and of high exposure level. Generally, the more frequently an individual’s normal behaviors are disrupted or the longer the duration of the disruption, the greater the potential for biologically significant consequences to individual fitness. The potential for biologically significant effects is expected to increase with the number of pile-driving events to which an individual is exposed.”
Empire Wind DEIS v.1, Page 3.15-14, PDF page 372
This warning is about risks created by pile driving but all forms of acoustic harassment fit this description. NOAA harassment authorizations are based on the estimated number of critters that will be exposed to unsafe sound levels. The source of the dangerous sounds is irrelevant. What matters most is the volume. Sound is a pressure wave; the louder the sound the greater the physical pressure on the hearing system. Pain and physical damage are possible.
In fact the infamous sonar surveying sounds, implicated in the whale deaths to date, can be much louder that the incredibly loud pile driving. Driving the enormous piles for the proposed wind projects is estimated to create sounds around 190 decibels, which is painfully loud in humans.
But some sonar equipment deliberately emits sounds over 200 decibels. Decibels is a log scale so this is not just 5% greater than 190; it is much greater.
Thus it makes no sense that NOAA claims sonar surveys have no significant impact and so do not fall under NEPA, while pile driving does. This is especially true when, as just happened, a dozen different projects are given simultaneous authorization to acoustically harass large numbers of whales.
What is important is that NOAA and a BOEM are clearly stating that the acoustic threats we have been warning about and suspecting are real. The telling correlations between sonar blasting and increased whale deaths cannot be waived away.
Correlation is not causation, but correlation between cause and predicted effect is very strong evidence that the cause is effective. NOAA and BOEM’s repeated insistence that there is no evidence offshore wind development is killing whales is clearly contradicted by their own Environmental Impact Statements.