PINNGORTITALERIFFIK GRØNLANDS NATURINSTITUT (GINR)

P.O.BOX 570, DK-3900 NUUK TEL (+299) 36 12 00 / FAX (+299) 36 12 12

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AARHUS UNIVERSITET DET NATIONALE CENTER FOR MILJØ OG ENERGI (DCE)

Bureau of Minerals and Petroleum

Att. Frederik Lynge

GINR J.nr. 61.00.20/12-01

Re: Comment to document about narwhal summer migration

On March 16, the BMP asked us to evaluate a note submitted by Shell International about the lack of

evidence of narwhal migration during July in northeastern Baffin Bay.

When evaluating the potential of disturbing narwhals with seismic activities in July in Baffin Bay, the

following points should be considered:

1. Narwhals from Melville Bay occur in winter in central Baffin Bay and during August-September in

coastal areas of Melville Bay.

2. Between winter and summer they migrate or move between the two areas including some periods

in spring where they have to wait for the ice to open. Exactly similar to the situation as have been ob-

served at the ice edge in Lancaster Sound (see Heide-Jørgensen et al. 2003).

3. During the 2004-2011 the Melville Bay had fast-ice in July that prevented the narwhals from enter-

ing the bay during 6 out of eight of the years. Only in 2008 and 2009 were the coastal areas of Mel-

ville Bay ice-free in July. And only in those two years were the narwhals able to enter the bay in July.

In the six other years the narwhals remained offshore in June-July while awaiting the disintegration of

the coastal fast-ice. Usually narwhals cannot enter the summering ground in Melville Bay before Au-

gust.

4. The average catch of 50 narwhals per month in July in Upernavik documents that narwhals are pre-

sent in northern Baffin Bay at this time of the year.

5. July is also part of the parturition season for narwhals and that is exactly the time of the year where

we don’t want to disturb the narwhals with seismic. It is not per se important whether the whales are

migrating or not, but what is important is that they are located offshore in areas where they can be ex-

posed to seismic activity. Disturbance of narwhals in the pack-ice areas or along ice edges should be

avoided, at least until we have better knowledge of the direct effects of seismic activity on narwhals.

In summary, we are still of the opinion that seismic surveys during July in Baffin Bay will risk dis-

turbing the migration to summering grounds of narwhals.

Mads Peter Heide Jørgensen and Fernando Ugarte (GINR)

David Boertmann (DCE)

March 19, 2012

Aarhus Universitet

Frederiksborgvej 399

Postboks 358

4000 Roskilde

E-mail: dmu@dmu.dk

http://www.dmu.dk/omdmu/afd

elingerorganisation/arktiskmiljo

e

Line Anker Kyhn

Jakob Tougaard

David Boertmann

Dato: 03. maj 2012

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DANISH CENTER FOR ENVIRONMENT AND ENERGY AARHUS UNIVERSITET

Modtager(e): Bureau of Minerals and Petroleum NOTAT

Regarding: The EIA by Maersk Oil Kalaallit Nunaat A/S on their

2012 Program Block 9 (Tooq) 3D-Seismic Survey and Hydrograph-

ic Survey

The bureau of Minerals and Petroleum has asked DCE to evaluate the EIA by

Maersk regarding their 2012 Program Block 9 (Tooq) 3D-Seismic Survey and

Hydrographic Survey.

Maersk suggests to perform a 1,900 km2 3D seismic survey in Tooq, as well as

to perform a hydrographic survey with a single airgun.

They suggest beginning the 3D survey in mid July and the hydrographic sur-

vey as soon as possible after permission to carry out this project, i.e. some

time in June.

The programme is intended to last for 2.5 months.

For the 3D seismic programme the source level of each airgun array is 263 dB

re 1 µPa (peak-peak), and will shoot alternating.

Major parts of this EIA appears copied from the EIA from ConocoPhillips. As

long as the content is the same this may be reasonable, however it makes both

EIAs appear rather superficial.

The hydrographic survey is not sufficiently described for evaluation of its po-

tential effects. There is no information on how the single airgun is intended

used and its physical properties have not been described as required. It is not

clear where and when it is intended to be used. On the map relating to the hy-

drographic survey only sample stations are shown. DCE recommends a speci-

fication on how the hydrographic survey is intended to be carried out. Please

refer to more comments and questions pertaining to this below.

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Regarding the noise model and mitigation:

A consideration of possible/likely population consequences of behavioural

disturbance is lacking. It is not clear why so few conclusions have been drawn

from the cumulative noise model of the combined four seismic surveys and

the shallow core drillings. Behavioural effects are considered moderate in ta-

ble 7.4-1, yet in the text it is stated that no population level effects are antici-

pated. It is completely unclear how such a conclusion can be reached. The

narwhals over-summer for a reason in Baffin Bay and even if we do not know

the reason behind this, it still means that displacement from this area could

displace animals from an essential resource.

The model is a means to evaluate potential effects on a larger scale combining

several activities and to suggest the mitigation required to reduce the poten-

tial cumulative effects. No suggestions are really made in chapter “7.4.1 Iden-

tification of Mitigation Measures” p 64, and at the same time it is not written

that there are no ways to mitigate. The risk of cumulative exposure to nar-

whals and belugas are considered moderate (on the scale: negligible, low,

moderate and severe). And still no mitigation measures are suggested. Why is

that? What mitigation measures are possible? Instead the Simultaneous Op-

erations Plan (SimOP) is mentioned as a mitigation plan, despite the fact that

it is common knowledge that the purpose of a SimOP is to ensure proper data

collection when multiple surveys are operating in the same area. This is not

satisfactory.

Also the results of the models are not really used. It is not assessed what it ac-

tually means for a narwhal or a ringed seal that the cSEL is up to 180 dB re 1

µPa2s over 24 hours within the Melville Bay Nature Reserve? What does that

translate into over the course of the proposed seismic survey?

A clear statement on the potential mitigation suggestions from Maersk with

respect to cumulative effects of the four proposed seismic surveys is request-

ed. How do Maersk suggests mitigating potential effects to marine mammals?

DCE does not understand how the conclusion of negligible effects to narwhals

and belugas can be justified when no studies exist on physical or physiological

effects of seismic surveys on narwhals and as long as no actual mitigation has

been suggested for the four combined surveys. The conclusion needs justifica-

tion.

DCE very much welcomes and appreciates Maersk’s mitigation initiative by

increasing the number of streamers to reduce the number of survey lines and

thus total time spent in the area. However, the distance between survey lines

for each streamer option is not stated in the EIA but is needed to evaluate the

actual effect of this mitigation suggestion. Also, upon reading the EIA this ef-

fort seems less certain, despite that maps with use of up to 12 streamers are

shown. In order to make this evaluation DCE would need to know what will

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determine the number of streamers and what the expected number of stream-

ers will be? DCE recommends that the total number of streamers is increased

as much as possible at all times. DCE also recommends that the streamer

spacing is increased when options with fewer streamers are chosen.

Maersk suggests expanding the safety zone from 500 to 600 m, however

based on the results from Jasco’s modelling, DCE advices that the safety zone

should be expanded to min. 730 m to avoid injury to any marine mammal.

This safety zone should also apply to shut down and ramp up procedures. If

marine mammals enter within this expanded safety zone the mitigation gun

should be used to deter further approach.

Questions/Comments

Page 3 ”… and 8, 10 or 12 Sercel Sentinel solid streamers, depending on sea

state, weather conditions, amount of glacial ice and other factors at the time

of survey”.

Maersk should at all times maximise the number of streamers to reduce the

number of survey lines and duration of the 3D survey. DCE would like to

know what the expected number of streamers will be and also what the

streamer spacing will be?

Page 3 ” Ship-specific procedures and measures will be developed by MOKN

and its Contractors for the work. These steps will be implemented during the

survey period to mitigate, reduce, prevent and/or manage effects of noise

generated during the Project.”

What will these measures be? How will they mitigate effects of the suggested

activities? Please describe actions and mitigation effects.

Page 4 ”MOKN will ask its seismic contractor to optimize and carefully man-

age operation of the array, such that only the correct amount of sound, and

not more than this amount, is being generated to meet the acquisition re-

quirements of the program.”

DCE would like to know the results of this. What changes will be made and

what will the final source level be?

Page 4 ” A multi-beam/single-beam bathymetry system, a side-scan sonar

system and sub-bottom profiling systems, as well as box coring, …, will be

used during the survey.”

Please provide data on source level and frequency content of these different

systems. Is the single airgun mentioned on page 38 included in this data sam-

pling? How will these data be collected? Will they run continuously or duty

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cycle? Where will the single airgun be sued? Is the single airgun included in

the modelling?

Page 6 ”… following, as a minimum, the August 2010 Joint Nature Conserva-

tion Committee (JNCC) Guidelines for Minimising Acoustic Disturbance to

Marine Mammals from Seismic Surveys. ”

Maersk shall follow the BMP 2011 guidelines regarding seismic surveys.

Page 6 ”In addition, MOKN will conduct test lines on location during the sur-

vey period. An airgun array smaller than 4,240 in3 will be tested to determine

if a reduced source size will be sufficient to image the target depths, despite

the outcome of the review mentioned above”

DCE acknowledges this approach. Will these tests potentially have influences

on the 2012 survey? When will the actual size of the array and source level be

determined, and what will it be?

Page 9 ” The estimated frequency of fog in an open sea area is 20% to 30% of

total time in July (Valeur et al. 1996)”

Please provide data for the relevant periods Aug-Oct.

Page 38 ” For the hydrographic survey, full-area acoustic modelling was con-

ducted using AASM and MONM considering the full 4240 in3 airgun array

and the single 60 in3 airgun.”

Where to does this single airgun belong? It’s use and source level is not de-

scribed anywhere. Please provide specifications and intended use.

Page 44.

Why are baleen whales not considered per se? Why only the bowhead whale?

Page 46 ” Sounds are less likely to disturb or injure animals if they are at fre-

quencies where the animal has low hearing sensitivity.”

What is this statement based on? At least porpoises react strongly to frequen-

cies below their own vocalization frequency and they get TTS at frequencies

very much lower than their own emitted frequencies.

Please provide arguments and references for this statement.

Page 47 ” Seismic surveys introduce high-amplitude sound into the marine

environment (200 to 250 dB re 1 uPa at 1 m)”

Without reference to peak-peak, rms etc this statement has no content. Sec-

ondly, it is likely an understatement since the intended 3D survey will use a

source level of 263 dB re 1 µPa (pp).

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p46 “Most of the sound produced from seismic surveys consists of low fre-

quency pulses at frequencies below 250 Hz with the strongest energies cen-

tered in the 10 to 120 Hz range (Goold and Fish 1998)”

Here it would be relevant to include the studies by DeRuiter et al. 2006 and

Madsen et al. 2006 that show that there is also energy at frequencies much

above what is used by the industry, especially in the low sound velocity sur-

face duct.

p47 “There is no direct evidence of sound from seismic surveys resulting in

acute physical damage to marine mammals in their natural marine setting.”

Here it would be correct to include Malakov 2002 reporting on stranded

beaked whales in response to seismic surveys, as well as Engels et al. 2004

reporting in stranded humpback whales following a seismic survey.

p 47. “To date, there is no record of either of these effects occurring in marine

mammals as a consequence of exposure to airgun pulses under realistic field

conditions.”

This is not correct. Please refer to the Lucke et al. 2009 study,the stranded

beaked whales (Malakov 2002) and stranded humpbacks (Engels et al. 2004).

p 47 “While the biological importance of behavioural changes is not well un-

derstood, the consequences will likely not cause measurable effects under

most circumstances” It would be correct to state that it is close to impossible to measure behav-ioural and physiological effects on wild marine mammals, rather than stating that there are no effects. It is not correct to use the lack of evidence as a proof of lack of effects. p 48 ” During the summer feeding season, bowhead whales appear to be less sensitive to seismic sound” It is not possible to conclude whether animals remaining in a disturbed area are less sensitive. It may as well be that the more hungry animals remain in the area, while the more fit animals leave the disturbed area. See Beale and Monaghan 2004.

p 48 ” In addition, audibility between pulses does not seem to be compro-

mised when marine mammals are exposed to plosive sound sources such as

seismic sounds (Abgrall 2008)”.

& ” However, masking effects are thought to be minimal due to the potential

for sound detection between airgun pulse intervals (Abgrall 2008”.

With a new airgun shot every ten seconds (considering one seismic survey on-

ly), reflections and interference between reflections, airgun pulses are

dragged out in time and is unlikely to disappear from the background noise

level before arrival of the next pulse. A recent study from Alaska by LGL

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(Blackwell et al. 2011) shows that bowhead whales simply stop vocalising

when the background noise level increases to a certain threshold in vicinity of

airgun arrays. And this is including the short periods between the pulses. It is

therefore highly likely that airgun arrays, and especially from multiple airgun

arrays, will cause masking of baleen whale hearing. Whether it may cause

masking of toothed whale communication and echolocation will depend on

range from the airgun array.

p48 “The frequencies contained in seismic pulses overlap with those used by

pinnipeds, but as discussed above for baleen whales, the discontinuous, short

duration of the pulses is expected to result in limited communication masking

in these animals; therefore, acoustic masking is not assessed further”

It is noted, that this sentence constitutes the entire chapter in the EIA report

regarding masking of pinnipids. This is very superficial and ignores potential

effects that need to be assessed. The results of the LGL study mentioned

above also apply to pinnipids.

Page 48-49 “... the onset of injury for cetaceans and pinnipeds was predicted

to occur at 590 meter (R95%) and 170 m (R95%), offset from the survey line,

respectively. … The cetacean exposure threshold for injury (180 dB re 1 uPa

(rms)) was used to determine safety zone radii as this was the more conserva-

tive of the two established NMFS exposure thresholds for injury. Therefore

apply a precautionary approach by increasing the safety zone to 600 metres,

(offset from the survey line), during seismic activities.”

On page 39 it is mentioned that the maximum range to an rms SPL of 180 dB

re 1 µPa is 710 m. In appendix D this was given as 730 m. A 600 m safety zone

will therefore only relieve part of the problem. To choose a proper safety zone

it would be appropriate to use the most conservative measure which is the

maximum range of 730, and then change the safety zone correspondingly to

800 m. Consider expanding the safety zone or provide arguments to why not.

p 49 “This extended safety zone is put in place to lessen the behavioural ef-

fects of seismic activities to whales from ConocoPhillips operations.”

How will an extended safety zone limit behavioural effects?

p 50 “… and most of the sound energy will be emitted outside the sensitive

frequency range for both species. ”

Please refer to the studies that conclude that cetaceans should react more to

sound of their own emitted frequency than to other frequencies. There is one

study on reaction of belugas to seismics clearly showing that they react

strongly by displacing themselves 20-30 km from the survey ship. How can

that be interpreted as if they are less prone to react behaviourally?

Page 50 “this airgun was previously assessed in Section 6.3.11.3.”

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On what pages was this airgun described? DCE did not find the source level

mentioned anywhere.

Page 50 ” For baleen whales, no physical effects are anticipated from sonar

pulses due to a lack of overlap of these sounds with the functional hearing

range of baleen whales.”

No hearing curves exist for baleen whales. Therefore it can not be concluded

that they cannot hear and will not be affected by sonars.

Page 51 ” Acoustic Masking”

DCE does not agree with the conclusion for baleen whales, pinnipids and the

walrus. LGL (Koski et al. 2011) has shown that the background noise level is

increased with 20 dB between airgun pulses despite their short lived nature.

Therefore masking is likely for all species utilising frequencies contained in

airgun pulses, as well as animals very close by the seismic survey.

Why is there no conclusion for baleen whales in general?

Page 52 The entire chapter on the hydrographic survey

There is no description of the single airgun or how it will be used. In table

6.3-3 an extended safety zone and use of MMSOs is mentioned as mitigation,

however in the chapter it is concluded that there are no effects expected from

the hydrographic survey. A description on how the single airgun is intended

used in order to evaluate its impact is needed. Including source level and oth-

er technical descriptions as called for in table 6.4.1 of the “Guidelines to envi-

ronmental impact assessment of seismic activities in Greenland waters 3rd

revised edition, Dec. 2011”. A description on how MMSOs are intended used

for mitigation, a map of the survey lines and all other perculiarities pertaining

to the use of the airgun is also needed.

Page 53 “Many toothed whales show considerable tolerance of ship traffic.

There is no available evidence of toothed whales abandoning parts of their

historical range because of vessel traffic (Richardson et al. 2005).”

Please provide references for the first statement. The second statement is very

coarse. Hereby you can omit the studies concluding that there a short term ef-

fects, for example the study by Finley 1990 on narwhals and belugas leaving

an area in response to approach by an icebreaker at very low received levels,

and too far away to be seen visually. The animals removed themselves up to

80 km away from the icebreaker. They also stopped vocalising and generally

reacted as though exposed to predators.

Page 54 “Table 6.3-4”

MMSOs are mentioned for mitigation of effects of vessel sounds. How will the

observers be used?

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How can the effects of vessel noise be considered regional, when the effects of

airgun pulses - of much higher source level - are considered local?

Page 55 “Ramping up the airgun array on the Asima, described in Section

3.6.4 of the EIA, and use of a mitigation airgun during line changes, if needed,

will also deter marine mammals from approaching this ship. It further reduc-

es the possibility of a ship strike.”

DCE agrees that ramp up and start of the mitigation gun, or other acoustic

equipment likely may deter marine mammals from closer approach, however

this possibility should not be the first priority during the risk of a ship strike

as the sound will disturb animals at much greater ranges than the animals at

risk and contribute to otherwise unnecessary noise pollution to that environ-

ment at that time. Rather the ship should change speed or direction.

Page 55 “they will spend as little time as possible in NPZ-II (autumn migrato-

ry corridor in Eastern Baffin Bay)”

Maersk shall leave the area before onset of the NPZ-II protection period on

15th October.

Page 58. When will the Ballast Water Management Plan be available for DCE/GN review?

Page 63 Table 6.7-2

The overall impact for sea birds of an oil spill is concluded to be low. This is

based on likelihood. However, such evaluation should consider worst case

scenarios.

Page 65. Table 7.3-1

It is a very large area within which the injury threshold is exceeded for pinni-

pids, and it is very likely that many seals will be present within this area.

How do Maersk intend to mitigate this?

The size of the total area exceeding the threshold for pinnipids in all block

varies between ConocoPhillips and Maersk - why?

Page 65 Table 7.3-1 (see also App. D page 50, table 30)

Where do the differences in ranges exceeding the pinnipid injury threshold

between the results stated in the EIA of ConocoPhillips and Maersk arise

from? For ConocoPhillips the total range from the line is 2450 m (270 m) and

for Maersk it is 1750 m (600 m). Does the difference arise from two lines be-

ing covered within 24 hours for Maersk, whereas it only covers one line for

ConocoPhillips? The source levels and firing rates are similar.

Page 66 ” In addition to MOKN applying these known and effective mitigation measures during its operations in Tooq Block, the three operators have

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agreed to discuss preparation of a Simultaneous Operations Plan related to multiple seismic surveys that occur at the same time in northeast Baffin Bay. Part of this Plan may include measures to further reduce the extent of poten-tial cumulative effects on marine mammals.” How will this plan provide mitigation? What measures will be taken? Normal-ly such plans only cover issues relating to insuring proper data collection by the different companies operating in the same area.

Page 66 “Table 7.4-1 summarizes the impact rating classifications for the cu-mulative effects of seismic sound on fish and marine mammals in Northeast Baffin Bay. These impact ratings are considered conservative, as the assess-ment was based on a multiple operations scenario where all proposed seismic programs are assumed to take place in a simultaneous fashion.” What is conservative? What is expected to be different in reality? Page 66 Table 7.4-1 1) The MMSOs can not mitigate behavioural changes. 2) Why is it considered unlikely that pinnipids will be masked? Page 67 ” Moreover, most of the sound energy from airguns is emitted outside the sensitive frequency range for both narwhals and belugas.” We agree it is unlikely that narwhals and belugas will get hearing damages, even if they were to be in Tooq at the time, because they’ll likely stay away. However, that is not related to the frequency content of the airgun signals, since even porpoises utilising much higher frequencies can get TTS from air-gun pulses (Lucke et al. 2009). Page 67 ” With known and effective mitigation in place, the probability of physical injury in toothed whales from cumulative exposure to seismic sound is considered rare, resulting in a negligible (1) impact significance rating for both beluga and narwhal”. We don’t agree to this statement that can only pertain to physical damages of the ear itself. We simply do not have the knowledge to state whether or not toothed whales may obtain other physical damages as a result of airgun noise. Such physical effects could be related to stress or/and changes in behaviour that may lead to physical effects, such as strandings as is seen in beaked whales (Malakov 2002) and humpbacks (Engels et al. 2004). It would be more correct to conclude that it is unknown to what degree physi-cal and physiological changes, perhaps a side from hearing damages, may arise as a result of exposure to multiple simultaneous seismic surveys.

Page 67 “The overall impact significance rating for behavioural effects from

cumulative sound exposures from seismic sound sources is predicted to be

moderate (3) for beluga and narwhal.”

It is not known how narwhals react to airgun noise, but it is known how they

react at great ranges and low received levels to icebreaker noise (Finley 1990).

Based on this it may be expected that they may be displaced at even low re-

ceived levels. Whether they quickly habituate and return is not known. What

this means to nursing whales is also not known. The results of the modelling

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of the four simultaneous surveys haven’t been discussed or considered suffi-

ciently.

Page 67

What is the conclusion for other baleen whales than bowheads?

Page 68 ” The cSEL injury threshold for pinnipeds (186 dB re µPa2-s; South-

all et al. 2007), based on results in the Acoustic Technical Report (Appendix

D), is predicted to be exceeded at distances up to 270 meters offset from the

survey line. The potential for auditory damage to pinnipeds from cumulative

sound exposure is thus considered to have a low magnitude, as the cSEL inju-

ry threshold will not extend outside the 600 m safety zone.”

The results from Southall et al. 2007 are for exposure within 24 hours. Within

24 hours the threshold will be reached in an area covering 57.9 km2. Do you

actually think you can mitigate that?

Page 68 ” Although the frequencies emitted by cumulative seismic pulses

overlap with those used by pinnipeds and walruses for communication, the

short duration of these pulses is not expected to result in communication

masking, as these animals will be able to emit and receive sounds between

airgun pulses (Davis et al. 1988)”

Silence or normal background noise levels can not be expected between puls-

es, as has been studied by LGL (Ksoki et al. 2011). Especially not with four

simultaneous surveys in the area firing at different times. Masking is to be ex-

pected for baleen whales, pinnipids and the walrus given they are in the area.

What the effect of this is, is not known.

Page 69-70 Regarding the simultaneous operation plan.

Normally such plans are only concerned with proper seismic data collection.

DCE would much welcome initiates here concerning mitigation of cumulative

effects.

Such could include planning to minimise the total exposed area and thereby

number of exposed animals, by keeping the four airgun vessels as close to-

gether as possible considering the data collection. Rather than keeping the

four vessels as separated as possible as this would increase the size of the ex-

posed area and thus number of exposed animals. Modelling of this scenario

was especially called for during the meeting on the 20th January in Copenha-

gen, but has not been including in the cumulative modelling scenarios.

Page 72 “The MMSOs will carry out observations in accordance with the

JNCC “Guidelines for Minimizing Acoustic Disturbance to Marine Mammals

for Seismic Surveys” and the DCE “Guidelines to Environmental Impact As-

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sessment of Seismic Activities in Greenland Waters”, both cited earlier sec-

tions of the EIA.”

The MMSOs shall follow the DCE guidelines made especially for Greenlandic

waters (Guidelines to Environmental Impact Assessment of Seismic Activities

in Greenland Waters) and not JNCC guidelines. This also applies for the data

collection methodology.

Page 72 “MOKN’s seismic contractor will employ the lowest practical power

levels to minimize unnecessary shooting, for example, through extended gun

tests or repeated acquisition at times of high background noise”

How will this be applied in practise? Will the source level actually ever be

lower than the stated 262.6 dB re 1 µPa (peak-peak)?

Page 72 “. Operations will be suspended if marine mammals are sighted with-

in 500 m of the airgun array.”

Above in the EIA a 600 m safety zone is suggested; DCE suggests a 800 m

safety zone as mentioned above. What will the safety zone be?

Page 72 “A daily log of sightings, observation locations and data will be main-

tained using the forms associated with the guidelines”

Data entering should follow the NERI guidelines, not the JNCC.

Page 72 “Passive Acoustic Monitoring Plan”

Are the PAM observers part of the four MMSO observers mentioned on page

72? Or do they come on top?

Page 72 “A certified PAM operator will use a PAM system on the Polarcus

Asima for monitoring on marine mammals (in lieu of visual monitoring) at

night, during periods of darkness, and during sea states greater than Beaufort

3.”

Periods of reduced visibility where PAM should be used also include fog that

precludes monitoring of the safety zone.

Page 90 Figure 4.1-11

What date are the profiles from?

Appendix D

General questions:

Do the SEL and cSEL values include the increased background noise levels in

between airgun pulses? If not, the stated values are more likely to represent a

minimum than a conservative estimate.

Further; the SEL values are lower than when adding the total number of shots

per survey – why?

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Page 12, table 3:

How come the single 60 in3 airgun hasn’t been included here?

What is the source level of the single airgun?

Page 14 fig 3

Why are the two modelled transect lines spaced so far a part? Are lines ex-

pected to be taken like this?

Page 50, table 30:

Here is stated that the area for which the 186 SEL Threshold

(dB re 1 µPa2s) is 2450 km2. In the EIA itself this is stated as 1750 km2. Which

is correct?

Appendix I

Page 4 ”(4) Use of NMFS interim noise exposure criteria for the onset of di-

rect physical injury in fish exposed to impulsive noise sources”

How will this mitigate injury in fish?

Page 6 ” (3) Ramping up of the airguns will also be used to deter marine

mammals from the area.”

This is discussed above. This option should be the last chosen due to the long

ranging noise emitted at the same time, which means that many more ani-

mals will be disturbed at the same time. Rather, if there are many animals in

the area, the speed should be decreased further below the stated max. 14

knots or the route should be changed.

Page 6 ”As possible, Project vessels will avoid marine protected areas and are-

as identified as important to marine mammals, specifically, the Melville Bay

Reserve and Narwhal Protection Zone (NPZ) IV (summer habitat near Qaa-

naaq; Project vessels will limit time spent in NPZ - I: (summer habitat area in

Melville Bay) and NPZ- II (autumn migratory corridor in Eastern Baffin

Bay).”

‘As possible’ seem inappropriate here: Maersk has no operations or activities

in NPZ-I and Maersk shall terminate all operations in NPZ-II before 15th Oc-

tober.

Page 7 “• Control at the source: airguns will be operated at lowest practicable

power levels”

When will the source level ever be lower than the stated 262.6 dB re 1 µPa

peak-peak? Please provide adequate information on when and where the

source level will be lower.

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Page 7 “The source/receiver ratio has been increased to reduce the number of

source shots transmitted per survey line, as well as the total number of seis-

mic lines required (provides for a reduction in the duration and extent of po-

tential noise effects)”

This initiative to mitigate is really good, however in the EIA 8, 10 and 12

streamer options are mentioned. DCE strongly recommend that the 12

streamer solution is used as often as possible, and that derivations from this

option are explained.

Page 7 “• The MMSO program will adhere to industry standard survey proto-

cols and NERI standards;”

The MMSOs shall adhere to NERI guidelines including how to collect data.

They shall not use data sheets or protocols made by JNCC.

Page 7 “Based on acoustical modelling completed by JASCO the project spe-

cific marine mammal safety radii was determined to be 600 m to avoid the

potential for injury to marine mammals;”

According to the results from Jasco presented in appendix D, the safety radii

should be at least 730 m to adequately reduce risk of injury.

Page 7 “Ramp up… increases over a minimum ramp-up period of 20 minutes,

thus…”

A ramp-up shall take about 20 minutes, not maximum or minimum 20 min.

Page 7 “Implementation of pre-shooting searches to determine that no ma-

rine mammals are present with the 600 m safety zone”

Remember here that the duration of the pre-search depends on the depth at

the site:

<200m: 30 min search

>200m: 60 min search

Page 7 “Implementation of shutdown procedures”

Based on the modelling results by Jasco, the 200 m safety zone for injury

should be expanded to minimum 730 m.

Page 7 ” If shooting of the airguns has stopped and not restarted for at least 10

minutes, then a pre-shooting search and 20 minute ramp-up will be complet-

ed. If the break is less than 10 minutes the MMSO will visually scan within the

600 m safety zone;”

If the airguns have been off for a period of less than 5 minutes they can be

restarted at full speed. For longer periods with the airguns off, a pre-search

and ramp up has to be conducted (BMP 2011 guidelines for seismic surveys in

Greenland waters).

Side 14/14

INSTITUT FOR BIOSCIENCE AARHUS UNIVERSITET

Page 7 ” Firing of airguns will be terminated at the end of each survey line and

a full 20 minute soft-start will be undertaken prior to starting the next

survey line, providing that the line chance time is less than 20 minutes.”

Again the pre-shooting search duration depends on the depth in the area.

Page 8 “Airguns will be operated at the lowest practicable power levels to

achieve the geophysical objectives of the proposed seismic survey”

This has been noted above, but please specify under what circumstances the

airgun output will be decreased from the stated 262.6 dB re 1µPa (peak-peak).

Page 8 “Seismic activities will be avoided in the designated narwhal protec-

tion zones (NPZ-I and NPZ-II) during the designated protection periods

where practical.”

Maersk shall finish activities in NPZ-II before 15th October, so the statement

“where practical” seems inappropriate. Maersk has no activities in NPZ-I.

PINNGORTITALERIFFIK GRØNLANDS NATURINSTITUT (GINR)

P.O.BOX 570, DK-3900 NUUK TEL (+299) 36 12 00 / FAX (+299) 36 12 12

Side 1 af 1

AARHUS UNIVERSITET DET NATIONALE CENTER FOR MILJØ OG ENERGI (DCE)

Bureau of Minerals and Petroleum

Att. Frederik Lynge

GINR J.nr. 61.00.20/12-01

Re: Comment to document about narwhal summer migration

On March 16, the BMP asked us to evaluate a note submitted by Shell International about the lack of

evidence of narwhal migration during July in northeastern Baffin Bay.

When evaluating the potential of disturbing narwhals with seismic activities in July in Baffin Bay, the

following points should be considered:

1. Narwhals from Melville Bay occur in winter in central Baffin Bay and during August-September in

coastal areas of Melville Bay.

2. Between winter and summer they migrate or move between the two areas including some periods

in spring where they have to wait for the ice to open. Exactly similar to the situation as have been ob-

served at the ice edge in Lancaster Sound (see Heide-Jørgensen et al. 2003).

3. During the 2004-2011 the Melville Bay had fast-ice in July that prevented the narwhals from enter-

ing the bay during 6 out of eight of the years. Only in 2008 and 2009 were the coastal areas of Mel-

ville Bay ice-free in July. And only in those two years were the narwhals able to enter the bay in July.

In the six other years the narwhals remained offshore in June-July while awaiting the disintegration of

the coastal fast-ice. Usually narwhals cannot enter the summering ground in Melville Bay before Au-

gust.

4. The average catch of 50 narwhals per month in July in Upernavik documents that narwhals are pre-

sent in northern Baffin Bay at this time of the year.

5. July is also part of the parturition season for narwhals and that is exactly the time of the year where

we don’t want to disturb the narwhals with seismic. It is not per se important whether the whales are

migrating or not, but what is important is that they are located offshore in areas where they can be ex-

posed to seismic activity. Disturbance of narwhals in the pack-ice areas or along ice edges should be

avoided, at least until we have better knowledge of the direct effects of seismic activity on narwhals.

In summary, we are still of the opinion that seismic surveys during July in Baffin Bay will risk dis-

turbing the migration to summering grounds of narwhals.

Mads Peter Heide Jørgensen and Fernando Ugarte (GINR)

David Boertmann (DCE)

March 19, 2012

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INUIT CIRCUMPOLAR COUNCIL · INUIT ISSITTORMIUT SIUNNERSUISOQATIGIIFFIAT

ICC HEAD OFFICE · AQQUSINERSUAQ 3A, 1ST FLOOR · P.O. BOX 204 · DK-3900 NUUK · PHONE +299 32 36 32 · FAX +299 32 30 01 · WWW.INUIT.ORG

Inuit Circumpolar Council, Greenland Høringssvar vedrørende Vurderinger af Virkninger på Miljøet (EIA) for ansøgte 3D seismiske

indsamling samt havbundsprøver og hydrografik i Nordvestgrønland af Maersk

Nuuk den 14. maj 2012 Inuit Circumpolar Council (ICC) har gennemgået den fremsendte Vurdering af Virkninger på Miljøet (VVM) af 3D seismiske undersøgelser samt havbundsprøver og hydrografiske undersøgelser i Blok 9 (Tooq), licensnummer 2011/15, Nordvestgrønland. Ansøgningen er indsendt af Maersk Oil Kalaallit Nunaat A/S, og dækker et areal på ca. 1.900 km2 og forventes at have en varighed på ca. 2½ måned fra juli. GENERELLE BEMÆRKNINGER ICC finder det positivt at Råstofdirektoratet har forlænget den offentlige høringsfrist til 8 uger, som er helt i tråd med ICC Grønlands tidligere anbefalinger. Det samme gælder for selskabernes frist til at indsende projektbeskrivelse senest 1. februar i det pågældende år. Særligt når der, som i år, er tale om 7 foreslåede olieefterforskningsprogrammer er det af afgørende betydning at der er tid til en grundig gennemgang af programmerne, således bliver det også lettere at få et overblik over mulige kumulative effekter af forskellige projekter. SPECIFIKKE KOMMENTARER I forbindelse med dette års seismiske aktiviteter har JASCO Applied Sciences fået udarbejdet en rapport med modellering af lydens udbredelse i farvandene omkring Baffin Bugt. Rapporten giver et bedre overblik over mulige kumulative effekter af flere seismiske projekter i området. Det lader dog til 12 at der ikke nævnes noget om skygge- og konvergenszoner. Dette er ellers blevet fremhævet af Madsen et al. (2006), da de arktiske farvande har stærkere lagdeling, der kan skabe særlige konvergenszoner, selv mange km væk fra selve lydkilden (op til 12 km), hvor lydtryks-niveauet pludseligt forstærkes og med højere frekvenser end planlagt. Dette kan igen have en effekt, ikke kun på bardehvaler, men også tandhvaler længere fra lydkilden. Hvorvidt modelleringen tager højde for disse mulige konvergenszoner fremgår ikke klart. ICC anbefaler at mulige effekter af efterforskningsaktiviteter generelt, så vidt muligt undersøges hos vilde dyr i deres naturlige miljø. Såfremt der refereres til undersøgelser hvor effekter er undersøgt med forsøg foretaget på dyr i fangeskab, bør der tages forbehold for dette og disse forbehold bør nævnes i EIA rapporterne. Det nævnes kort i EIA’en og i det ikke-tekniske resumé at de anvendte fartøjer er is-klassificerede. IMO’s retningslinjer for skibe, der opererer i polære farvande (IMO Guidelines for Ships Operating in Polar Waters 2009) anbefaler netop at fartøjer som minimum bør være af is- eller polar-klasse. Selvom retningslinjerne er frivillige, betragter ICC Grønland dem som udtryk for best practice, og sætter pris på at ConocoPhillips har valgt at følge dem. Det nævnes også kort at fartøjerne følger SOLAS 1974 regler, BMP og DCE og andre relevante retningslinjer. Dog er oplysningerne om fartøjerne i øvrigt mangelfulde, da det ikke fremgår hvilken is-klasse de har, og der i øvrigt ikke er en oversigt over andre fartøjsdata, som har været tilfældet i en del andre EIA’er. Det vil gøre det lettere at

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INUIT CIRCUMPOLAR COUNCIL · INUIT ISSITTORMIUT SIUNNERSUISOQATIGIIFFIAT

ICC HEAD OFFICE · AQQUSINERSUAQ 3A, 1ST FLOOR · P.O. BOX 204 · DK-3900 NUUK · PHONE +299 32 36 32 · FAX +299 32 30 01 · WWW.INUIT.ORG

få et hurtigere overblik hvis sådan en oversigt indsættes. ICC anbefaler i øvrigt at oplysningerne om fartøjernes sikkerheds-miljøforanstaltninger verificeres af relevante uafhængige søfartssagkyndige. ICC Grønland vil gerne meddele, at dette høringssvar gerne må offentliggøres på Selvstyrets hjemmeside. ICC Grønland lægger også høringssvaret ud på sin egen hjemmeside www.inuit.org under Aktiviteter → Offentlige høringer i Grønland. ICC takker for fortsat at være høringspart, og ser frem til fortsat samarbejde.

Ineqarnermut, Attaveqarnermut Angallannermullu Naalakkersuisoqarfik

Departementet for Boliger, Infrastruktur og Trafik

1/1

Råstofdirektoratet

Frederik Lynge

3900 Nuuk

IAANs svar til høring vedr. indsamling af seismiske data

Infrastrukturkontoret skal gøre opmærksom på, at operatører, der ønsker at foretage

charterflyvninger til godkendte flyvepladser i Grønland, skal have en tilladelse fra Trafik-

styrelsen. Operatører, der ønsker at foretage cabotageflyvning i Grønland, uden at have

en forudgående tilladelse, skal have en beflyvningstilladelse fra Trafikstyrelsen og Grøn-

lands Selvstyre i henhold til IAANs og Trafikstyrelsens procedurer herfor.

Infrastrukturkontoret har ikke yderligere kommentarer til høringen, da det er IAANs for-

ståelse, at

• projektet ikke involverer etablering af infrastrukturanlæg på land

• de aktiviteter, der søges om, vil blive reguleret i henhold til international og nati-

onal søfartslovgivning

Inussiarnersumik inuulluaqqusillunga

Med venlig hilsen

Asbjørn Rosager

Toqq/direkte 345113

asro@nanoq.gl

24. apr 2012

Sagsnr. 2012-065245

Dok. Nr. 889678

Postboks 909

3900 Nuuk

Tlf. (+299) 34 50 00

Fax (+299) 34 54 10

E-mail: iaan@nanoq.gl

www.nanoq.gl

1

Frederik Lynge

Fra: Martin Schjøtz-Christensen <Martin@business.gl>

Sendt: 9. maj 2012 11:10

Til: Frederik Lynge

Cc: Marie Fleischer; Kaare Winther Hansen; Anne Sofie Hardenberg; Inger Christiansen

Emne: FW: VS: VS: Offentlig høring af miljøvurderinger om planer for kulbrinteaktiviteter i

Baffin Bugt

Kære Frederik Lynge,

Behandling af disse 4 høringer er i Kommuneqarfik Sermersooq henlagt til administrativ besvarelse, via Sermersooq

Erhvervsråd (SBC)

SBC har inntet at bemærke i denne forbindelse. Selv om samtlige høringer vedrører områder uden for Sermersooq, sætter

vi pris på orienteringen.

Inuulluaqqusillunga // Med venlig hilsen // Best Regards Martin Schjøtz-Christensen Projektleder, Sermersooq Erhvervsråd

Project Manager, Sermersooq Business Council (+299) 34 10 85 // (+299) 58 86 24

martin@business.gl

Nuukullak 35, P.O.Box 1051, 3900 Nuuk, GreenlandTel: +299 341080 Fax: +299 311554

Look us up at: www.sermersooq.com and www.business.gl

Fra: Frederik Lynge [mailto:FRL@nanoq.gl]

Sendt: 19. marts 2012 20:04

Til: Jørgen T. Hammeken-Holm

Emne: Offentlig høring af miljøvurderinger om planer for kulbrinteaktiviteter i Baffin Bugt

Kære alle

Råstofdirektoratet har i dag bragt nedenstående 4 miljøvurderinger af planer for kulbrinteaktiviteter i Baffin Bugt,

Nordvestgrønland, i offentlig høring via høringsportalen www.nanoq.gl. I tilfælde af hel eller delvis imødekommelse af

aktivitetsplanerne, vil disse blive sat i værk i løbet af sommeren/efteråret 2012.

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Høringsfristen udløber mandag den 14. maj 2012 kl. 12.00.

1. ConocoPhillips Global NVE Greenland Ltd., operatør på eneretstilladelse nr. 2011/11 (Qamut), har ansøgt om

godkendelse af plan om indsamling af 2D seismiske data fra det af tilladelsen omfattede område. Selskabet

har udarbejdet en miljøvurdering, på engelsk kaldet Environmental Impact Assesment (”EIA”), som kan findes

på følgende link: http://dk.nanoq.gl/Service/Hoeringsportal/Miljøvurderinger/2012/ConocoPhillips.aspx.

2. Shell Kanumas A/S, operatør på eneretstilladelserne nr. 2011/12 (Anu) og 2011/14 (Napu), har ansøgt om

godkendelse af plan om indsamling af 3D seismiske data fra det af tilladelserne omfattede område. Det

planlagte indsamlingsområde rækker delvist ind over det af eneretstilladelse nr. 2011/11 (Qamut) omfattede

område. Shell Kanumas A/S har udarbejdet en EIA, som kan findes på følgende link:

http://dk.nanoq.gl/Service/Hoeringsportal/Miljøvurderinger/2012/Shell.aspx.

3. Maersk Oil Kalaallit Nunaat A/S, operatør på eneretstilladelse nr. 2011/15 (Tooq), har ansøgt om

godkendelse af plan om indsamling af 3D seismiske data inklusive en hydrografisk undersøgelse og

indsamling af havbundsprøver fra det af tilladelsen omfattede område. Selskabet har udarbejdet en EIA, som

kan findes på følgende link:

http://dk.nanoq.gl/Service/Hoeringsportal/Miljøvurderinger/2012/Maersk%20Oil%20Kalaallit%20Nunaat.aspx.

4. Shell Kanumas A/S, operatør på forundersøgelsestilladelse nr. 2011/60, har ansøgt om godkendelse af plan

for udførelse af stratigrafiske boringer med udtagelse af 11 borekerner fra 7 forskellige lokaliteter i Baffin

Bugt. Selskabet har udarbejdet en EIA, som kan findes på følgende link:

http://dk.nanoq.gl/Service/Hoeringsportal/Miljøvurderinger/2012/Borekonsortiet.aspx.

Interessenterne bedes være opmærksomme på, at høringsmaterialet kan findes i både den grønlandske og den danske del af høringsportalen.

Hvis høringsanmodningen giver anledning til spørgsmål, kan disse rettes til Råstofdirektoratet.

Venlige hilsener

Frederik

Inussiarnersumik inuulluaqqusillunga / Med venlig hilsen Frederik Lynge Sulianik ingerlatsisoq, Aatsitassanut immikkoortortaqarfik / Sagsbehandler, Mineralafdelingen, Oliesektionen

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Aatsitassanik Ikummatissanillu Pisortaqarfik Råstofdirektoratet Tlf: (+299) 34 68 00 (arbejde) Postboks 930 Tlf : (+299) 34 68 37 (direkte) Imaneq 29, B1685 DK - 3900 Nuuk Fax: (+299) 32 43 02 Hjemmeside: www.nanoq.gl & www.bmp.gl Mail: frl@gh.gl DISCLAIMER: The information in this email is confidential. The contents may not be disclosed or used by any- one other than the addressee. If you are not the intended recipient(s), any use, disclosure, copying, distribu- tion or any action taken or omitted to be taken in reliance on it is prohibited and may be unlawful. If you have received this communication in error please notify us by e-mail or by telephone on +299 34 68 00 and then delete the e-mail and all attachments and any copies thereof. Bureau of Minerals and Petroleum (its subsidiaries and associates) cannot accept responsibility for the accu- racy or completeness of this email as it has been transmitted over a public network. If you suspect that the email may have been intercepted or amended, please call the sender.

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